Pollution and Office Firms: Why “Not Applicable” Is the Right Answer
When small office-based companies start their CSRD or VSME sustainability reporting, one question often causes confusion: “Do we have to report air or water pollution?”
For most professional, IT, and digital service SMEs, the honest and correct answer is: ✅ “Not applicable.”
Here’s why that response is perfectly valid — and how to document it properly in your sustainability report. For office-based business guidance, see CSRD for office SMEs.
Why Pollution Isn’t Material for Office-Based SMEs
The Corporate Sustainability Reporting Directive (CSRD) asks companies to disclose impacts that are material — meaning they are significant either to the environment or to your business.
Under the VSME Standard (Basic Module, B4), pollution covers emissions of:
- Greenhouse gases (already covered under B3)
- Air pollutants (e.g. NOₓ, SO₂, PM10, PM2.5)
- Water pollutants (e.g. nitrates, phosphates, heavy metals)
- Soil pollutants (e.g. oil, chemicals)
These apply to industrial, agricultural, or energy-intensive activities — not to office environments where emissions are limited to everyday electricity use, commuting, and cleaning products.
So unless your company:
- Operates a laboratory or manufacturing site,
- Handles chemical substances or hazardous waste, or
- Has legally monitored air or water discharges,
…the correct and compliant answer under B4 – Pollution is “Not applicable”.
How to State “Not Applicable” Correctly
When filling out your VSME or CSRD disclosure table, don’t leave B4 blank. Instead, explicitly note that pollution is not material and explain why.
Example wording for your report:
“The company operates in a standard office environment with no direct emissions to air, water, or soil. Activities do not involve manufacturing or hazardous materials. Pollution is therefore not considered material under VSME B4.”
If your firm uses cleaning products or IT equipment, you may add:
“All cleaning and maintenance products are commercially available and used in standard quantities. No regulated pollutants are generated.”
This level of disclosure meets both VSME and CSRD proportionality expectations.
What You Still Need to Report Instead
Even if pollution is not applicable, other relevant areas should still be covered:
| Relevant Topic | VSME Section | Example Data |
|---|---|---|
| Energy and GHG emissions | B3 | Office electricity and heating (Scope 2) |
| Water use | B6 | Annual consumption from utility bills |
| Waste management | B7 | Office recycling and e-waste |
| Employee commuting (optional) | Scope 3 | Qualitative information |
By reporting these topics, you demonstrate accountability without overstating immaterial areas.
How “Not Applicable” Protects Your Credibility
Marking pollution as “not applicable” is not avoidance — it’s responsible reporting. The CSRD and VSME frameworks explicitly recognise proportionality for SMEs: you should only report what is relevant to your business model and risks.
Over-reporting (adding irrelevant metrics) can actually:
- Confuse readers and dilute focus,
- Suggest poor understanding of materiality, and
- Create unnecessary administrative work.
Correctly identifying non-material topics shows you’ve assessed environmental impact thoughtfully, a key expectation under CSRD Article 19a (Materiality and Risk Assessment).
When Pollution Might Become Relevant
Reassess annually. Pollution may become material if you:
- Begin operating data centres or server rooms with refrigerant gases,
- Install backup generators or fuel storage,
- Manage on-site maintenance with chemical use, or
- Expand into hardware refurbishment or manufacturing.
If these apply, you can later update your disclosure to include quantitative data or narrative on mitigation measures.
Example Disclosure Template
| VSME Section | Disclosure | Comment |
|---|---|---|
| B3 – Energy and GHG | 42 MWh electricity, 10.5 tCO₂e | Based on supplier invoices |
| B4 – Pollution | Not applicable | No emissions to air, water, or soil |
| B6 – Water use | 180 m³ | From utility bills |
| B7 – Waste | 1.8 tonnes (70% recycled) | Office waste and e-waste recycling |
Key Terms
- CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
- VSME: Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
- B4 – Pollution: VSME disclosure on emissions to air, water, and soil
- Materiality: Relevance and significance of a sustainability topic to your operations
- Scope 2 emissions: Indirect GHG emissions from purchased energy
- Scope 3 emissions: Other indirect emissions, e.g. from commuting or suppliers