CSRD Reporting for Small Energy Suppliers and Solar Installers
Europe’s energy transition relies heavily on small and medium-sized energy suppliers, solar installers, and renewable technology providers. Many of these businesses are not directly in scope of the Corporate Sustainability Reporting Directive (CSRD), but they play a crucial role in the energy value chain and will increasingly be asked to provide sustainability data to larger corporate clients, municipalities, and financiers.
This guide explains how small energy providers and solar installers can report effectively under the Voluntary Sustainability Reporting Standard for SMEs (VSME) — making CSRD compliance simpler and more transparent for their customers. For related guidance, see renewable energy SMEs reporting and waste and material reporting for solar panel installers.
1. Who Needs to Report and Why It Matters
Under CSRD
Large energy companies, utilities, and listed groups must report detailed sustainability information under Directive (EU) 2022/2464. This includes:
- Energy generation and supply emissions (Scopes 1–3)
- Environmental and social impacts
- Transition and resilience plans
For SMEs
Most independent energy suppliers, installers, and micro-grid developers fall below CSRD thresholds:
- Fewer than 250 employees
- Less than €40 million turnover
- Less than €20 million in total assets
However, they are often part of CSRD-regulated value chains — supplying power, equipment, or services to large utilities or municipalities. These clients need sustainability data for their own reporting.
The VSME Standard (EFRAG, 2024) offers a proportionate framework for such SMEs to disclose this data voluntarily, helping maintain partnerships and access to finance.
2. Choosing the Right Reporting Approach
The VSME Standard provides two modules:
| Module | Description | Best for |
|---|---|---|
| Basic Module (B1–B11) | Core disclosures: general info, energy, emissions, workforce, and governance | Solar installers, local energy co-ops |
| Comprehensive Module (C1–C9) | Adds targets, climate risks, human rights, and diversity data | Growing energy SMEs or suppliers to listed utilities |
Start with the Basic Module; add selected Comprehensive disclosures as your reporting matures.
3. Core Reporting Topics for Energy SMEs
Below are the most relevant VSME Basic Module disclosures for energy-sector SMEs:
| Code | Topic | Example Data for Small Energy Firms |
|---|---|---|
| B1 | Basis for preparation | Legal form, NACE 35.14 (electric power distribution) or 43.21 (electrical installation) |
| B2 | Sustainability practices | Renewable sourcing, grid loss reduction, worker training |
| B3 | Energy and GHG emissions | Own energy use, emissions from vehicles, and purchased electricity |
| B4 | Pollution | Fuel storage, air emissions, refrigerant leaks |
| B5 | Biodiversity | Impact of solar farms or installations on land use |
| B7 | Resource use and waste | Solar panel packaging, cable waste, battery recycling |
| B8–B10 | Workforce | Health & safety, fair pay, training hours |
| B11 | Governance | Anti-corruption and compliance statements |
4. Step-by-Step: How to Report Energy and Emissions (B3)
Step 1 – Collect Data
Record your direct energy use (Scope 1) and purchased electricity (Scope 2):
- Vehicle fuel use (litres)
- Office/workshop electricity and heating
- Generator use (for off-grid operations)
Step 2 – Convert to MWh
Use standard conversion factors:
- 1 kWh = 0.001 MWh
- 1 litre diesel = 0.010 MWh
- 1 m³ natural gas = 0.011 MWh
Step 3 – Estimate GHG Emissions
Apply CO₂ conversion factors:
- Electricity: 0.25 kg CO₂/kWh (EU average)
- Diesel: 2.68 kg CO₂/litre
- Natural gas: 0.20 kg CO₂/kWh
Step 4 – Calculate GHG Intensity
Divide total CO₂ emissions by turnover to show efficiency (kg CO₂ per €1,000 turnover).
Example: GreenSpark Solar Ltd emitted 24 tonnes CO₂e in 2024 on €3.2 million turnover = 7.5 kg CO₂/€1,000 turnover
Step 5 – Describe Improvement Measures
Under B2, outline how you’re reducing emissions:
- Upgrading to EV vans or hybrid vehicles
- Powering offices and depots with renewables
- Training teams in energy-efficient installations
5. Reporting Resource Use and Waste (B7)
Solar and electrical SMEs handle materials with recycling obligations.
| Waste Type | Common Source | Good Practice |
|---|---|---|
| Packaging | Panels, batteries, inverters | Use certified recycling partners |
| Scrap cables | Installations | Sort and sell to recyclers |
| Solar modules | End-of-life panels | Partner with WEEE-compliant collectors |
| Batteries | Energy storage systems | Return to manufacturer take-back schemes |
Disclose:
- Total waste generated (hazardous vs. non-hazardous)
- Recycling rate (%)
- Circular practices (e.g., component reuse)
Example: “In 2024, 3.4 tonnes of installation waste were recycled (92% recovery rate).”
6. Workforce and Safety Reporting (B9–B10)
Energy fieldwork involves height, electrical, and thermal hazards. Report annually on:
- Number of employees and contractors
- Training hours (especially safety and electrical certification)
- Recordable incidents and lost-time accidents
- Pay equality and minimum wage compliance
Example summary:
“Our team of 28 employees completed 320 safety training hours with zero lost-time injuries in 2024.”
7. Governance and Ethics (B11)
Under B11, disclose:
- Any convictions or fines for corruption/bribery (if none, state this)
- Certification (e.g., ISO 9001, ISO 14001)
- Internal controls on procurement and ethical sourcing
This strengthens transparency when working with public authorities or large corporate customers.
8. Example VSME Summary for a Solar SME
Company: SunPeak Installations Ltd NACE Code: 43.21 – Electrical installation Employees: 35 Reporting Year: 2024 Module: Basic
| Disclosure | Indicator | 2024 Result |
|---|---|---|
| B3 – Energy use | 118 MWh (100% renewable electricity) | Scope 1: 7.2 tCO₂e; Scope 2: 0 tCO₂e |
| B7 – Waste | 4.2 tonnes (non-hazardous) | 96% recycled |
| B9 – Health & Safety | 1 recordable accident | 320 hours training |
| B10 – Pay Equity | Female pay gap: 4% | Above minimum wage |
| B11 – Governance | No fines/convictions | ISO 14001 certified |
SunPeak aims to reduce fleet fuel emissions by 20% by 2025 through EV adoption.
9. Linking to CSRD Value Chain Reporting
Under Articles 19a and 29a of the CSRD, large utilities must disclose sustainability impacts across their value chains, including subcontractors and suppliers.
By adopting the VSME structure:
- Small suppliers provide standardised, verifiable data
- Large clients can easily integrate this into ESRS E1 (Climate) and E5 (Resource Use) disclosures
- The SME demonstrates responsible partnership and readiness for future sustainability obligations
10. Quick Wins for Energy SMEs
| Area | Action | Benefit |
|---|---|---|
| Fleet Management | Switch to EVs or biofuels | Cut Scope 1 emissions |
| Procurement | Choose recycled or low-carbon materials | Strengthen circular economy score |
| Office Energy | Install rooftop solar or LED systems | Reduce operating costs |
| Customer Services | Offer lifecycle emissions estimates | Improve transparency |
| Data Management | Use digital meter and fuel apps | Simplify VSME reporting |
Key Terms
- CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464).
- VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG 2024).
- Basic Module – Entry-level sustainability reporting for SMEs.
- Comprehensive Module – Optional advanced disclosures for larger SMEs.
- Scope 1, 2, 3 Emissions – Direct, energy-related, and value-chain emissions.
- GHG Intensity – Emissions relative to turnover.
- WEEE – Waste Electrical and Electronic Equipment Directive.
- ESRS – European Sustainability Reporting Standards for large companies.