I don't have a sustainability report but still have to complete a list
No VSME report is not a problem, but a choice per question
Without a VSME report, you can still answer — only not with a reference to that report. VSME is EFRAG's voluntary standard for non-listed SMEs, established in response to the demand for sustainability data via the CSRD chain (Directive 2022/2464). It is not a legal obligation for SMEs themselves; larger customers often simply request the basic module because they must provide that information themselves to their reporting chain. If you have no report, you fall back on the underlying facts: energy consumption, number of employees, locations, waste figures. These are often already recorded somewhere, just not in VSME form.
The system recognises VSME-like questions — scope 1 and 2 emissions, water consumption, workforce diversity — and searches the chain file for an answer based on facts, not for the existence of a report. Some fields can be filled directly from basic data that is already on record, such as the number of employees or the countries where the company has establishments. Other questions — for example exact CO2 figures per scope — the file may not have. Then the system does not propose a "yes" for which there is no source; that question remains open until you yourself provide a figure or consciously indicate "not yet available". You confirm each proposed answer with yes or no, so you see per question which part is based on a fact and which part you must supplement yourself.
Why this distinction follows from the VSME framework
The basic module of EFRAG VSME is designed so that undertakings without a formal reporting system can still answer in a structured way, with factual data items instead of a mandatory certification or reporting format; hence the absence of a report is not an obstacle to sharing the underlying data.
What this is based on
- Trade Register Act 2007 — the data recorded for each company
- EFRAG VSME — the voluntary standard for non-listed SMEs, basic module
- Directive (EU) 2022/2464 (CSRD)
- ISO/IEC 27001 — Annex A, the control measures
- Directive (EU) 2022/2555 (NIS2), Article 21(2) — the ten measures
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.