how do I know if the list I receive is a VSME list or something more extensive
Two versions with a significant difference in depth
First look at the number of data points and whether a double materiality analysis is requested. A VSME list (the voluntary basic module of EFRAG for unlisted SME companies) requests a limited, standardized set: energy consumption, scope 1 and 2 emissions, water consumption, personnel data, and a few governance questions. No scope 3, no materiality analysis, no assurance requirement. A CSRD list (based on Directive (EU) 2022/2464) is the full reporting set via the ESRS standards: it does request scope 3, does request a double materiality analysis, and often substantiation per sub-theme with policies, targets and actions.
The practical signal is in the length and wording. If the list asks for "material IROs" (impacts, risks, opportunities) or for an assurance statement from an auditor, then it is a CSRD list, even if the customer themselves is not CSRD-obligated but is passing on the requirements through the chain. If the list remains limited to a table with quantitative key figures and a few yes/no questions about policies, then it is usually VSME. If you are unsure, the answer often cannot be established with certainty from the list itself — sometimes the name of the standard is simply stated above it, sometimes not. In the latter case, it helps to look at whether the number of employees and the annual turnover that are requested in the list, align with a threshold: CSRD lists often ask for this precisely to determine whether the customer themselves falls under the directive.
Where the distinction comes from
The difference does not follow from a single article, but from the scope of Directive (EU) 2022/2464 itself: that directive requires a defined group of large and listed companies to report according to the ESRS standards, while the VSME is a standalone, voluntary product of EFRAG, intended to remain just below that threshold without having to provide the full set. A list that reaches an SME supplier through the chain is therefore always a derivative: the customer chooses which format they send on. Also the sector of the company can play a role: some sector-specific ESRS standards are still under development, so a list that refers to them is by definition a CSRD list and not a VSME.
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
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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.