What is VS (formerly VSME)?

VS, the Voluntary Standard, is the EU's voluntary sustainability reporting standard for companies with fewer than 1,000 employees. The Commission adopted it on 3 July 2026 as Delegated Regulation C(2026) 5011, supplementing the Accounting Directive 2013/34/EU. It replaces VSME, which was a Commission recommendation, (EU) 2025/1710.

If you have been asked for sustainability data by a customer, a bank or in a procurement, VS is in most cases the common format for the answer.

From VSME to VS

VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs) was developed by EFRAG and issued as Commission Recommendation (EU) 2025/1710 on 30 July 2025. It was aimed at non-listed small and medium-sized companies, generally companies with up to 250 employees.

With VS, the standard has a new legal form and a larger target group:

The content is broadly the same. Anyone who has already reported under VSME will recognise it, but references in reports and sales material should now point to VS and C(2026) 5011.

Why does the standard exist?

Large companies have to report on sustainability under EU rules and need data from their suppliers to do so. Banks and investors need similar data. Without a common format, a small company ends up answering many different questionnaires about the same thing.

The standard therefore gives small companies a ready-made format that:

• covers the data large customers ask of their suppliers,
• covers what banks and investors need for financing,
• helps the company get a grip on its own environmental and workforce issues.

VS also adds clearer protection against large companies pushing too many requirements down the supply chain; more on that below.

How is VS structured?

The standard has two modules.

The basic module contains eleven disclosures, B1 to B11. It is the minimum for anyone reporting under the standard:

The comprehensive module builds on the basic module and adds data that banks, investors and larger customers often ask for, such as strategy, climate targets and climate risks. You have to report the basic module in order to report the comprehensive one.

Not every disclosure applies to everyone

Several disclosures are conditional:

• B4 applies if the company already reports pollutant emissions under law or in an environmental management system.
• B5 applies if the company has sites in or near biodiversity-sensitive areas.
• B11 only applies if there has been a conviction.

For the smallest companies, with ten employees or fewer, B3, B6 and B7 are among the voluntary disclosures.

What B3 requires of the climate figures

For most companies, B3 is the most demanding disclosure. Energy consumption is split into renewable and non-renewable, separately for electricity and for fuels. For emissions from purchased electricity (scope 2), VS requires the location-based figure. A market-based figure may be reported as voluntary additional information and should then be labelled as such.

Is VS mandatory?

No. VS is a voluntary standard. A company that reports under it does so on its own initiative, and the report is self-reported: no third party has reviewed or assured the content unless the company has ordered such a review itself.

In practice, though, customers often decide. A large company that needs data from its suppliers will ask, and it is easier to answer with a report in a format the customer recognises.

What may a large customer require?

Each data point in VS is marked as required, required if applicable, voluntary or sector-specific. These markings are the basis of what is called the value chain cap: a limit on which data a company with more than 1,000 employees may require, for reporting purposes, from a supplier with fewer than 1,000 employees.

• Required data may be requested by the customer.
• Required if applicable data may be requested when relevant, for example scope 3 emissions at a company where they are significant.
• Voluntary and sector-specific data may not be required for reporting purposes.

The cap applies to reporting. A customer can still ask for more information for other purposes, such as managing its own climate risks. According to the timetable known in autumn 2026, the cap applies from 1 January 2027, and how the rules would be transposed into Swedish law was not yet settled at that time.

Having the right to say no does not always make it wise to do so. Often the customer asks because it needs the data, and a good answer can be a competitive advantage.

Common mistakes in a first report

• Zero instead of "data not available". A zero means something did not happen. If the data is missing, the report should say so.
• No breakdown of energy. A single renewable percentage is not enough; B3 asks for the breakdown per energy type.
• Renewable electricity next to scope 2 emissions without an explanation. If the renewable share is based on contracts and guarantees of origin but the emissions figure is location-based, the report needs to explain this. Otherwise it appears to contradict itself.
• Outdated reference. A report that cites VSME or Recommendation 2025/1710 should be updated to VS and C(2026) 5011.
• Words that promise too much. Without third-party review, the report is self-reported. Avoid words such as "verified" or "audit-proof".

Getting started

1. Find out which disclosures apply to your company. Start with the basic module and see which conditional disclosures apply.
2. Collect the data. Much of what B3 needs, such as electricity, heat and fuel, is already in the bookkeeping as supplier invoices.
3. Keep what you know apart from what you have estimated, and state which method and emission factors you used.
4. Keep the source documents so every figure can be traced back to its source if the customer asks.

Washproof does steps 2 to 4 for you by reading the bookkeeping from Fortnox or an SIE file and producing a report under VS where every figure can be traced to its voucher. If you want help from someone outside the company, you can book advice from a senior sustainability advisor.

Sources

• Commission Recommendation (EU) 2025/1710 of 30 July 2025 on a voluntary sustainability reporting standard for small and medium-sized undertakings, OJ L 2025/1710.
• Commission Delegated Regulation C(2026) 5011 of 3 July 2026 (Voluntary Standard).