VSME Basic vs Comprehensive Module: Which to Choose?

For small and medium-sized enterprises (SMEs) across Europe, the Voluntary Sustainability Reporting Standard for SMEs (VSME) provides a simple and credible way to share sustainability information with clients, investors, and banks — without the complexity of full CSRD or ESRS reporting.

But the VSME offers two routes: the Basic Module and the Comprehensive Module. So which one should your SME use?

This guide compares the two side by side — showing what’s included, who each is for, and how to make a practical choice.

1. What Is the VSME Standard?

The VSME (Voluntary Sustainability Reporting Standard for SMEs) was developed by EFRAG in 2024 to help non-listed SMEs align voluntarily with the Corporate Sustainability Reporting Directive (CSRD).

It’s designed for companies that are not legally required to publish CSRD sustainability reports but still need to respond to client or lender data requests as CSRD deadlines approach.

The VSME lets SMEs:

• Disclose key ESG data in a proportionate and standardised format
• Reuse the same data across multiple client or supplier questionnaires
• Build trust and readiness for future sustainability expectations

The VSME has two levels of detail — the Basic Module (B1–B11) and the Comprehensive Module (C1–C9).

2. Overview: Basic vs Comprehensive

Both are fully voluntary and compatible with ESRS, meaning SMEs can start simple and scale up when needed.

3. The Basic Module (B1–B11): The Foundation for All SMEs

The Basic Module is designed to be achievable by any SME, even without a sustainability department. It focuses on what’s material, measurable, and manageable.

Structure of the Basic Module

What Makes the Basic Module Ideal for SMEs

• Quick to complete – can be prepared using existing data (invoices, HR records, policies)
• Minimal technical language – no need for a sustainability expert
• Flexible – applicable to any sector, from law firms to manufacturers
• Reusable – data can be shared with multiple CSRD-reporting clients

Tip: Most SMEs can prepare their Basic Module report in under 10 pages. Use our CSRD requirements checklist to track your progress.

4. The Comprehensive Module (C1–C9): Going Deeper into ESG

The Comprehensive Module is optional. It builds on the Basic Module for SMEs that:

• Work with large CSRD-reporting customers;
• Seek green loans or ESG-linked finance; or
• Already collect detailed environmental or social data.

Structure of the Comprehensive Module

When to Choose the Comprehensive Module

• You’re part of a supply chain for listed or multinational clients;
• You want to align with ESRS standards without being legally bound by CSRD;
• You already have a certified system (ISO 14001, ISO 45001, or CSR policy) and want to consolidate disclosures;
• You’re preparing for sustainability-linked loans or ESG ratings.

5. Which Module Should You Choose?

Practical approach: Start with Basic to create your first sustainability statement. Then, when clients ask for details (e.g. Scope 3 emissions or human rights policies), add relevant Comprehensive sections. You can also consider using software tools versus manual reporting to streamline data collection.

6. Effort and Time Comparison

7. Common Mistakes When Choosing a Module

1. Over-reporting too early: Starting with Comprehensive before your firm has data systems in place can lead to incomplete or unreliable results.

2. Ignoring client expectations: Some SMEs stick to Basic even when key clients already request Scope 3 data — leading to repeated follow-up requests.

3. Treating reporting as a one-time exercise: Both modules expect annual updates and continuous improvement — even if small steps each year.

8. How to Transition from Basic to Comprehensive

1. Finish your Basic Module (B1–B11) — this builds your sustainability foundation.
2. Collect data gradually — expand to Scope 3 emissions, risk assessments, and diversity tracking.
3. Add Comprehensive sections (C1–C9) as your data maturity grows.
4. Optional: seek limited assurance or external validation once you publish Comprehensive data.

Tip: Many SMEs publish their first Basic report in year one and add 3–4 Comprehensive disclosures in year two.

9. Example: A Practical SME Pathway

10. Key Takeaways

• Start with Basic: it’s accessible, low-cost, and covers all major ESG topics.
• Upgrade to Comprehensive: when your clients, investors, or regulators need deeper data.
• Both modules are voluntary: choose based on your firm’s size, data availability, and client expectations.
• The path is flexible: you can transition at any time — the structure is designed to scale with you.

Key Terms

For a complete explanation of CSRD terminology, see our glossary: CSRD, VSME, ESRS explained in plain English.

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
• Basic Module (B1–B11) – Core disclosures for all SMEs: energy, waste, workforce, governance
• Comprehensive Module (C1–C9) – Advanced disclosures covering strategy, targets, value chain, and risks
• ESRS – European Sustainability Reporting Standards (used under CSRD)
• Scope 1–3 emissions – Direct and indirect greenhouse gas emissions
• Materiality – Determining which ESG issues are most relevant to your business
• Turnover – Total annual revenue, used to calculate GHG intensity

Not sure which module is right for your company? Use our interactive recommender to find out:

This tool will help you understand which module (Basic or Comprehensive) fits your business size, industry, and reporting needs.