Sustainability reporting for SMEs: what still applies after the Omnibus and how the VSME helps

Few SMEs must publish a sustainability report, but customers and banks still ask: answer them once, from one data set.

In this topic: Sustainable business 11

No report required, but the questionnaire still lands on your desk

What the CSRD still asks after the EU Omnibus, what customers and banks may request from smaller suppliers, and how the VSME turns it into one data set.

Sustainability reporting for SMEs has turned from a publishing job into a data job. After the EU Omnibus, very few companies must publish a sustainability report. Yet a large customer still sends its supplier questionnaire, the bank asks for your energy use at the loan review, and a tender wants your emissions, each in its own format.

This page covers the practical side: what still applies, what you may be asked and what you may decline, and how to build the answers once. The strategic choices behind it are in sustainability strategy.

Who still has to report under the CSRD after the Omnibus?

The Corporate Sustainability Reporting Directive (CSRD) decides which companies include a sustainability report in their management report. The Omnibus I directive narrowed it to undertakings that exceed both a net turnover of €450 million and an average of 1,000 employees, for financial years starting on or after 1 January 2027 (source: EUR-Lex, February 2026). Those companies report under simplified European Sustainability Reporting Standards (ESRS), which apply from the same financial years (source: EUR-Lex, September 2026).

Your situation	What applies, in principle
Above both thresholds	A CSRD report under the revised ESRS
Below the thresholds, in the EU	No CSRD duty. You may use the voluntary standard, and with an average of 1,000 employees or fewer you are protected by the value-chain cap (source: EUR-Lex, February 2026)
Outside the EU, selling to EU customers	No direct duty unless your group has a large EU business, but EU customers will still ask for data

A directive still needs national law

Each member state writes the Omnibus changes into its own law, sometimes later than the EU text. If your company is near the thresholds, ask your accountant which rules apply to your financial year. This page explains principles, not legal advice.

What can large customers and banks still ask of smaller suppliers?

The value-chain cap protects smaller companies from overloaded questionnaires. A company that reports under the CSRD may not require a protected undertaking, one with an average of 1,000 employees or fewer, to provide more information than the voluntary standard specifies, and the smaller company may decline anything beyond it (source: EUR-Lex, February 2026). The cap is set out in a Commission delegated regulation and applies from financial years beginning on or after 1 January 2027 (source: EUR-Lex, July 2026).

The cap list in that regulation is short. It mainly covers the following areas (source: EUR-Lex, July 2026):

Area	Typical information on the cap list
General	Basis of the report, legal form, sector, size and locations; from the comprehensive module, main products, markets and business relationships
Energy and climate	Total energy consumption in MWh and estimated greenhouse gas emissions
Water and waste	Water withdrawal, waste by type and the share sent for recycling or reuse
Workforce	Employees by contract type and gender, recordable work accidents, pay against the minimum wage, collective bargaining coverage, training hours; from the comprehensive module, employee turnover
Conduct	From the comprehensive module: a code of conduct or human rights policy, a complaints mechanism and confirmed incidents

The cap concerns what a reporting company requests for its sustainability report. A bank weighing the climate risk of a loan, a tender or a negotiation can still raise other questions, which you answer on commercial grounds; a VSME report covers most of them.

What is the VSME and which module do you need?

The VSME, the voluntary sustainability reporting standard for SMEs, was written by EFRAG, the EU's technical adviser on reporting standards, and recommended by the Commission in July 2025. The Omnibus makes a Commission standard based on that recommendation the reference for voluntary reporting and for the cap (source: EUR-Lex, February 2026). It does not ask for the double materiality assessment that CSRD companies carry out, and its two modules build on each other.

Basic module

Practices and policies, energy and emissions, pollution, biodiversity, water, resources and waste, workforce, health and safety, pay and training, and corruption convictions. For the smallest firms some energy and emissions datapoints are voluntary.

Comprehensive module

Adds detail for firms with larger customers or lenders, such as strategy and business relationships, emission targets, climate risks and human rights. It can only be used on top of the basic module (source: EUR-Lex, July 2026).

How do you build one sustainability data set?

Nearly every figure already sits in your administration. The work is collecting it once a year, in the same units, with the method written down. For emissions, use the scopes of the Greenhouse Gas Protocol: scope 1 for your own fuel, scope 2 for purchased electricity and heat, scope 3 for the wider value chain (source: GHG Protocol, March 2004). Our page on the carbon footprint explains the calculation step by step.

Datapoint	Where it comes from	Watch out for
Energy use	Energy bills, meter readings, fuel cards	Convert gas volumes and fuel litres to kWh with your supplier's factor
Emissions	Energy use multiplied by emission factors	State which factors and which year you used
Water and waste	Water bills, waste contractor invoices	Ask the contractor for weights per waste stream
Employees	Payroll	Say whether you count heads or full-time equivalents
Accidents and training	Incident log, HR records	Use the same definitions every year

Example: one data set for three requests

Brenmoor Components machines metal parts, has 85 employees and €14.2 million revenue. Two customers and its bank ask for sustainability data in the same quarter. Finance manager Tom Adeyemi builds the energy and emissions part of a VSME basic report first.

Source	Energy	Emission factor	Emissions
Electricity (scope 2)	1,240 MWh	0.30 t CO2e per MWh	372.0 t
Natural gas (scope 1)	610 MWh	0.18 t CO2e per MWh	109.8 t
Diesel for vans (scope 1)	18,000 litres, 180 MWh	2.7 kg CO2e per litre	48.6 t
Total	2,030 MWh		530.4 t

Fictitious Firmfocus example. Emission factors are rounded illustrations; use the factors your energy supplier or national authority publishes for the reporting year. The logic works in any currency.

Scope 1 is 109.8 + 48.6 = 158.4 t and scope 2 is 372.0 t. Per million euros of revenue that is 530.4 / 14.2 = 37.4 t, the intensity figure both customers ask for. The first questionnaire took Tom four days; with the data set ready, the second took half a day and the bank's request an hour. One customer also wants a full inventory of supply-chain emissions. That goes beyond the basic module, so from the 2027 financial year Brenmoor may decline it; Tom offers an estimate for purchased steel, the largest category, because the customer is a key account.

How to answer a supplier sustainability questionnaire

01
Ask what it is for
A CSRD report, a tender, a risk check or a loan: the purpose decides what you may decline.
02
Map each question to the VSME
Most questions match a VSME datapoint. Where you can, send your VSME report instead of retyping it.
03
Answer from the data set
Use the same figures everywhere and label estimates as estimates.
04
Decline politely what goes beyond the cap
Refer to the value-chain cap, offer what you have and say when more might follow.
05
Update once a year
Refresh the data set when you close the books and keep the invoices and logs behind each figure.

ISSB and sustainability reporting outside the EU

Outside the EU the reference is the International Sustainability Standards Board (ISSB) of the IFRS Foundation, whose standards on general disclosures and on climate are written for investors. More than 40 jurisdictions have decided to use them or are taking steps to introduce them (source: IFRS Foundation, April 2026). They apply mainly to listed and large companies; smaller firms meet them through customers and lenders asking for the same data the VSME covers.

Market	Position in principle
United Kingdom	UK versions of the ISSB standards are final and available for voluntary use; the government and the Financial Conduct Authority are considering requirements (source: GOV.UK, February 2026)
United States	No federal climate disclosure rule in force after the SEC voted to stop defending its rules; check state laws where you do business
Canada	Adoption of ISSB-based requirements still to be determined (source: IFRS Foundation, April 2026)
Australia	Entities that prepare financial reports under the Corporations Act and meet size thresholds prepare a sustainability report with climate disclosures (source: ASIC, July 2026)

Small firm or supplier to large groups: what changes?

Small firm with a few business customers

The basic module is enough. Spend a day collecting energy, waste and staff figures, and reuse them for every request.

Mid-sized supplier to large groups

Expect several questionnaires a year and bank questions on transition risk. Add the comprehensive items your main customers need, appoint one owner for the data set and check your green claims against the same figures.

Common pitfalls in sustainability reporting for SMEs

Working from old thresholds: many guides still describe the CSRD before the Omnibus.
Refusing outright: declining everything beyond the cap is your right, but a short VSME report keeps the relationship and the contract.
Different figures in different places: a customer and a bank comparing your answers will notice.
Hidden estimates: estimates are fine when they are labelled and the method is stated.

Reporting is one of the rules covered under sustainable business. Data requests often arrive together with purchasing conditions, covered in sustainable procurement, and many of the same figures feed your energy efficiency obligations.

Does my SME have to publish a sustainability report?

Almost certainly not. After the Omnibus, the CSRD applies only to undertakings above both the turnover and the employee threshold. You may still choose to prepare a voluntary report so you can answer customers and lenders from one document.

What is the VSME?

A voluntary sustainability reporting standard for smaller companies, developed by EFRAG and used by the European Commission as the basis for voluntary reporting and for the value-chain cap. It has a basic and a comprehensive module.

Can I refuse a customer's sustainability questionnaire?

If you are a protected undertaking, you may decline information that a reporting customer requests beyond the voluntary standard, from the financial years in which the cap applies. In practice, answering the questions the standard covers and declining the rest politely works better than refusing everything.

Is the VSME useful outside the EU?

Yes, as a structure. It asks for the energy, emissions, workforce and conduct data that customers and lenders in most markets want, so a firm in the UK, North America or Asia supplying European groups can use it as its standard answer.

Sources

EUR-Lex: Omnibus I directive on sustainability reporting and due diligence (February 2026)
EUR-Lex: Delegated regulation on the voluntary standard and the value-chain cap (July 2026)
EUR-Lex: Delegated regulation simplifying the ESRS (September 2026)
WRI and WBCSD: GHG Protocol Corporate Standard (March 2004)
IFRS Foundation: Update on the ISSB's activities (April 2026)
GOV.UK: UK Sustainability Reporting Standards (February 2026)
ASIC: Sustainability reporting (July 2026)

Maak gebruik van onze ondernemerstools en de laatste branche-informatie

Verkrijg direct toegang tot alle stappen, downloads en tools voor ondernemers.

Toegang tot de meest actuele bedrijfstakcijfers
Ondernemingsplan online tool — schrijf en download naar MS Word
Download tools en templates voor ondernemers
Vergelijk en bewaar uw eigen cijfers met het branchegemiddelde

Verkrijg direct toegang