What anti-corruption disclosures do SMEs need for CSRD?

When small and growing businesses (SMEs) think about sustainability reporting, the first things that come to mind are usually energy, water, or waste. But governance — especially how a business prevents corruption and bribery — is also an important part of the Corporate Sustainability Reporting Directive (CSRD).

Most SMEs are not directly required to report under CSRD. However, your bank or larger customers may still expect you to provide information in line with the Voluntary Sustainability Reporting Standard for SMEs (VSME).

1. Why anti-corruption reporting matters

Banks and large corporate clients need to demonstrate that their supply chains are free from corruption risks. Even a single conviction can raise concerns about reliability.

For SMEs, being able to report a clean record is straightforward and can actually be a positive point of trust and credibility.

2. The basic disclosure requirement (VSME Basic Module)

Under the VSME Basic Module, the anti-corruption disclosure is very specific:

• If your business has faced convictions or fines for corruption or bribery in the reporting year, you must disclose:
  1. The number of convictions; and
  2. The total amount of fines.

If there were none, simply state this. For example:

“In 2024, [Company Name] recorded no convictions or fines relating to anti-corruption or anti-bribery laws.”

This requirement is listed as Disclosure B11 in the VSME standard.

3. Going further (Comprehensive Module and CSRD links)

The VSME Comprehensive Module includes additional governance disclosures that some SMEs may be asked for:

• C8: Revenues from restricted sectors — e.g. fossil fuels, tobacco, weapons.
• C9: Gender diversity ratio in the governance body — if your business has a formal board.

By contrast, large companies in scope of CSRD must go further: they are expected to explain their policies, processes, and risk management systems for preventing corruption and bribery, not just list convictions and fines.

4. Practical steps for SMEs

To stay prepared:

• Keep a record of any legal proceedings or regulatory actions (even if none).
• Log a “nil disclosure” each year if there are no cases, so you have a consistent record.
• Document your compliance measures (e.g. whistleblowing policies, employee training, supplier code of conduct).
• Be transparent — a clear statement of “no convictions or fines” is often sufficient.

Key Terms

• Corporate Sustainability Reporting Directive (CSRD) — An EU law requiring large companies (and eventually some medium ones) to report on their environmental, social, and governance impacts. Smaller suppliers are not directly in scope but may be asked for CSRD-style data.
• Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified framework to help SMEs disclose sustainability information, aligned with CSRD but voluntary.
• Basic Module — The minimum set of disclosures under VSME, covering key environment, social, and governance data.
• Comprehensive Module — An extended set of disclosures sometimes requested by banks or large clients.
• SME (Small and Medium-sized Enterprise) — A business with fewer than 250 employees, turnover under €50m, or balance sheet under €25m.
• Anti-corruption disclosure (B11) — The requirement to report the number of convictions and total fines for corruption or bribery in the reporting year.

While this guide focuses on anti-corruption, you may also need to identify which Scope 3 categories apply to your business:

This tool will help you understand the full scope of sustainability reporting, including value chain considerations.