Stop Answering ESG Questionnaires One by One: The Voluntary Standard (Formerly VSME) in 10 Minutes

If you supply larger businesses, you know the pattern. A customer sends a sustainability questionnaire, and you spend days gathering the data. Then another customer sends a different one, asking for much the same information in a different format.

 There is a better way to handle it, and it has just become more formal. The standard formerly known as VSME is now the Voluntary Standard (VS). Here is what it is, what changed, and why it matters before your next financial year starts. 

What is the Voluntary Standard? 

The Voluntary Standard is a simplified, standardised framework for reporting sustainability information. It is designed for companies that aren’t subject to mandatory reporting under the CSRD. It gives you one recognised structure for your data, rather than a new format for every customer, bank or investor who asks.

It covers broadly the same topics as the European Sustainability Reporting Standards (ESRS), which apply to companies in CSRD scope, but in a much simpler form.

Why was VSME renamed?

VSME began life as EFRAG’s standard for small and medium-sized entities, published in December 2024. On 3 July 2026, the European Commission formally adopted it through a delegated act. By then its scope had widened to companies with fewer than 1,000 employees, so “SME” no longer fitted, and it became the Voluntary Standard.

If customers or older guidance still say “VSME”, it’s the same standard in an earlier form. The final version groups datapoints into categories, removes and reallocates some, and moves detailed implementation guidance to EFRAG’s Knowledge Hub.

Key dates

• 3 July 2026: adopted by the Commission
• 21 September 2026: published in the Official Journal
• 24 September 2026: entered into force
• Financial years beginning on or after 1 January 2027: the standard applies

For a calendar-year business, 2027 is your first year in scope.

How does it work? 

The standard has two modules.

The Basic Module covers general information plus:

• Environmental metrics: energy and greenhouse gas emissions, pollution, biodiversity, water, resource use and waste
• Workforce metrics: workforce characteristics, health and safety, remuneration, collective bargaining and training
• Governance: convictions and fines relating to corruption and bribery

Micro-undertakings (10 employees or fewer) can stop here. Everyone else should treat the Basic Module as the minimum.

The Comprehensive Module adds information that banks, investors and business partners are likely to request. You need to report under the Basic Module first.

Datapoints are grouped as Required, Required if applicable, Voluntary and Sector-specific, although labelling isn’t yet consistent. It’s worth getting advice on what applies to you

How could it end the questionnaire cycle? 

The standard also sets the Value Chain Cap, an upper limit on the sustainability information large reporting companies can request from smaller ones. Under the cap, a company with fewer than 1,000 employees may decline requests that go beyond the standard’s listed datapoints, and micro-undertakings are measured against a reduced version. Requests for other purposes, such as due diligence, aren’t affected.

An important caveat: Austria has already written the cap into national law. Ireland is still transposing the Omnibus I Directive, and the Department of Enterprise, Tourism and Employment has said it intends to legislate during 2026, ahead of the March 2027 deadline. Until Irish law is in place, don’t assume you can refuse a request.

Even so, a Voluntary Standard report gives you a credible, recognised answer to hand to customers. It also gives you a solid basis for asking them to accept it.

Is it really voluntary? 

Legally, yes. Commercially, expect to be asked about it. A few points make it easier to take on:

• Flexible publication. You can send the report to stakeholders, integrate it into your management report, or publish it on your website.
• Aligned timing. The reporting period should match your financial year, with comparatives expected from your second year.
• Protection for sensitive information. You may leave out information that would harm your competitive position or reveal trade secrets.
• EMAS overlap. If you already prepare an EMAS environmental statement, you can combine it with your Voluntary Standard report.
• Optional assurance. Assurance isn’t required, but it can make your report more credible.

Where to start 

1. Check which module fits. Micro-undertakings can begin with the Basic Module.
2. Collect what you already hold. Energy bills, HR records, health and safety logs and management system records are often a good start.
3. Work out which datapoints apply to you. Don’t assume every one is required.
4. Align with your financial year. Your first full reporting period under the standard begins on or after 1 January 2027.
5. Decide how you’ll publish.

 Starting before the year begins gives you time to find gaps while there’s still room to fix them. 

Ready to answer once and answer well? 

At CG Business Consulting, we help Irish businesses turn the Voluntary Standard into a clear, practical reporting plan. 

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This article is for general information and isn’t legal advice. Information reflects sources available at 13 October 2026. Check the Official Journal for the final texts.

Sources: A&L Goodbody, Sustainability reporting and due diligence update (October 2026) · Forvis Mazars, VS vs. VSME overview

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