VSME vs CSRD: which report do you need?
After the Omnibus directive, the answer is simpler than it was in 2024. The CSRD is mandatory only for companies with more than 1,000 employees and over EUR 450 million net turnover, reporting under ESRS. The VSME is the EU's voluntary standard for SMEs, built to answer banks and customers. Most mid-size companies now need the second, not the first.
The two frameworks compared.
| CSRD (ESRS) | VSME | |
|---|---|---|
| Legal status | EU directive, mandatory for companies in scope | Commission Recommendation (EU) 2025/1710, voluntary |
| Who | More than 1,000 employees and more than EUR 450m net turnover (Directive (EU) 2026/470); non-EU groups above EUR 450m EU net turnover | Non-listed SMEs and micro-undertakings |
| First report | 2028 on FY2027 for wave-2 companies in the new scope | Any time |
| Standard | ESRS; revised (simplified) ESRS mandatory from FY starting 1 January 2027 | EFRAG VSME: Basic Module (B1–B11), optional Comprehensive Module (C1–C9) |
| Materiality | Double materiality assessment required | No full double materiality assessment |
| Climate data | ESRS E1, including Scope 3 where material | Scope 1 and 2; Scope 3 not required |
| Assurance | External limited assurance required | None required |
| Role in the value chain | Large companies collect supplier data | Designed as the cap on what large companies and banks request from SMEs |
Status 5 November 2026. Directive (EU) 2026/470 in force since 18 March 2026; transposition by 19 March 2027.
Three questions decide it.
1. Are you over both thresholds? More than 1,000 average employees and more than EUR 450 million net turnover, at group level. If yes, you are in CSRD scope and report under ESRS; the VSME is not an alternative. If no, you have no CSRD duty once national transposition lands. Wave-1 companies below the thresholds should check their Member State's timing.
2. Who is asking you for data? A bank, a customer or a tender. Because the VSME is designed as the cap on value-chain requests, a clean VSME report is the efficient answer to most of them. One dataset instead of five questionnaires.
3. Does a customer need Scope 3 or targets? The Basic Module covers Scope 1 and 2. If a buyer asks for reduction targets, add the Comprehensive Module (C3). If they ask for Scope 3, add a Scope 3 inventory alongside.
Who ends up where.
Customer questionnaire on emissions and labour data. → VSME Basic Module, plus Scope 1 and 2 inventory.
Bank ESG questionnaire with climate-risk questions. → VSME with Comprehensive Module (C3, C4).
Above both thresholds. → CSRD under ESRS, first report 2028 on FY2027, double materiality first.
Most mid-size companies left the CSRD in 2026. Their customers' questions did not.
Frequently asked.
Is the VSME a replacement for the CSRD?
Who has to report under the CSRD after the Omnibus?
Does the VSME require Scope 3?
Does a VSME report need assurance?
Can a company switch from VSME to CSRD later?
Know which report you need in one call.
Tell us headcount, turnover and who is asking. You get a written answer and a fixed-fee quote within 48 hours.