Updates to the VSME Module: Aligning with the Latest EU Guidance

With the Omnibus Directive, the Voluntary Sustainability Reporting Standard for SMEs (VSME) gained greater importance. In response, a dedicated VSME module was introduced in our platform, providing an immediate starting point for reporting based on the documents available at the time.

Since then, while the standard itself has not changed, both EFRAG and the European Commission have continued to provide guidance, clarifications, and practical improvements:

• On 16 June 2025, EFRAG released the 2nd version of its VSME Digital Template. This Excel-based questionnaire now includes automated calculations, interactive fields, and built-in guidance. These refinements reduce manual work and make reporting more intuitive.

• On 30 July 2025, the European Commission published the Commission Recommendation (EU) 2025/1710. The Recommendation, also available in German, further refines terminology within the VSME framework to ensure consistent usage across Europe.

Update of the VSME questionnaire

To keep our customers fully aligned with these developments, we have updated our VSME questionnaire. These improvements will:

• Ensure consistent terminology, reflecting the Commission’s Recommendation, especially in the German version.

• Incorporate the enhanced usability and automation introduced by EFRAG’s digital template.

Flexibility and Transparency in Calculations
With the updated VSME questionnaire, we provide both greater automation and flexibility:

• Integrated calculations: Additional fields enable calculations directly within the tool, making results transparent and traceable, without external spreadsheets.
• Optional input values: Values used in suggested calculations are not mandatory. Leaving fields empty does not affect compliance and provides clarity.
• Editable calculations: Suggested calculation methods remain editable, allowing the calculation itself to be adjusted if needed. The suggestions come from the official guidance and the digital template.

This update is not a correction of the initial version but the next logical step: The original VSME reporting module was implemented early, and the refinements published by the European institutions over the summer are now integrated. All previously entered data has been fully retained.

The result: an even more user-friendly VSME module that saves time and remains closely aligned with the official guidance.

What Has Changed in Detail

With the latest update to our VSME module, several datapoints have been added, refined, or enhanced to improve reporting accuracy, provide automated calculation support, and ensure consistency with the latest guidance. Key changes include:

General information:

• B1 24e: The information on the number of employees has been supplemented by two additional data points that capture the counting method used.

Environmental:

• B3 G15 (for Cooperatives): If the undertaking is a cooperative, three new datapoints are now available:

  • Effective participation of workers, users, or other interested parties/communities in governance.

  • Financial investment in the capital or assets of social economy entities (excluding donations and contributions).

  • Limits to the distribution of profits connected to the mutualistic nature or services of general economic interest (SGEI).

• B3 29: Energy consumption breakdown now follows the "If-applicable principle", meaning it only needs to be reported if information is available.

• B3 29: A new line allows disclosure of self-generated electricity.

• B3 30b: New datapoints for calculating total Scope 1 and Scope 2 GHG emissions, plus additional voluntary datapoints on market-based Scope 2 emissions.

• B3 31: Automatic calculation added to calculate GHG intensity.

• B3 52: Automatic sum of Scope 3 emissions introduced.

• B3 53: Added datapoints to disclose Total Scope 1, Scope 2, and Scope 3 emissions (both location-based and market-based)

• B6 36: A table has been added to automatically calculate water consumption.

• B7 38a: Automatic sum of of hazardous and non-hazardous waste introduced.

• B7 38b: Automatic calculation table added for total annual waste.

Social:

• B8 39b: Added a line “Not reported” for employee count.

• B8 40: Automatic calculation table added for employee turnover rate.

• B9 41a: Automatic calculation table added for rate of recordable work-related accidents.

• B10 42b: Automatic calculation table added for pay gap.

• B10 42c: Automatic calculation table added for percentage of employees covered by collective bargaining agreements.

• B10 42d: Added “Not reported” option for average annual training hours per employee.

• B10 42d: : Automatic calculation table added for average number of annual training hours per employee.

• C5 59: Automatic calculation table added for female-to-male ratio.

• C9 65: Automatic calculation table added for gender diversity ratio.

Governance

• C7 62a: New sub-datapoint to describe other incidents among the company’s own workforce.

• C7 62b: Actions taken to address incidents (previously a sub-datapoint) are now reported as an individual datapoint.

• C8 63c: Added lines for breakdown of fossil fuel revenues.

• B11 43: Clearer, highlighted reference to anti-corruption and bribery included.

Terminology Updates (German Version):

Several German terms have been updated to reflect the Commission’s Recommendation and ensure consistency:

• umfassendes Modul → Zusatzmodul (Comprehensive Module)

• Anwendbarkeitsprinzip → Falls-zutreffend-Grundsatz (if applicable principle)

• B2 Praktiken → Verfahrensweisen (Practices)

• C3 Treibhausgasreduktionsziele und Klimawandel → THG-Reduktionsziele und Übergang für den Klimaschutz (GHG Reduction Targets and Climate Transition)

• C4 Klimarisiken → Klimabedingte Risiken (Climate Risks)

• B5 Biologische Vielfalt → Biodiversität (Biodiversity)

• B7 Abfallmanagement → Abfallbewirtschaftung (Waste Management)

• B9 Gesundheit und Sicherheit → Gesundheitsschutz und Sicherheit (Health and Safety)

• B10 Entlohnung, Tarifverhandlungen und Weiterbildung → Vergütung, Tarifverhandlungen und Schulung (Remuneration, Collective Bargaining, and Training)

• C5 Arbeitskräfte → Beschäftigte (Employees)

• C8 Einnahmen → Umsatzerlöse (Revenue)