VSME Basic Module: what to report in B1 to B11

The Basic Module of the VSME standard has eleven disclosures. Two are short texts, nine are numbers you mostly already have in bills, payroll and your waste contract. Here is what each one asks, a worked example and a template.

What the Basic Module is

EFRAG published the Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME) on 17 December 2024 [1]. It has two modules: a Basic Module and a Comprehensive Module. The Basic Module is the target approach for micro-undertakings and the minimum for other companies that use the standard [1]. The Comprehensive Module adds disclosures on top of it, often the extra data that banks and investors want.

The European Commission then adopted Recommendation (EU) 2025/1710 on 30 July 2025, which recommends this standard to SMEs and asks companies that request sustainability data from SMEs in their value chain to keep their requests within it [2]. In 2026 the Commission turned the standard into a Delegated Regulation, the Voluntary Standard, based on the VSME with changes kept to a minimum [3]. So the B1 to B11 structure below is still the useful starting point, but check the current text before you publish.

The eleven disclosures, in plain language

The Basic Module has two narrative disclosures (B1 and B2) and nine metric disclosures (B3 to B11) [1].

Code	Topic	What you actually collect
B1	Basis for preparation	Legal form, sector, size, sites, which module you use, the reporting period
B2	Practices, policies and future initiatives	Which sustainability topics you have practices or policies on, and what you plan
B3	Energy and greenhouse gas emissions	Energy bills (electricity, gas, fuel) and scope 1 and 2 emissions
B4	Pollution of air, water and soil	Pollutant data you already report to an authority or permit holder
B5	Biodiversity	Sites in or near sensitive areas, land use
B6	Water	Water withdrawal, from meter readings or bills
B7	Resource use, circular economy and waste	Waste invoices from your waste contractor, split by type
B8	Workforce: general characteristics	Headcount by contract type and gender, leavers
B9	Workforce: health and safety	Recordable work accidents, fatalities
B10	Remuneration, collective bargaining and training	Pay gap inputs, collective agreement coverage, training hours
B11	Convictions and fines for corruption and bribery	Number of convictions and total fines, usually zero

Step by step: a first report in five steps

Pick the period. Use your financial year so the numbers match your accounts.
Collect the paper trail. Twelve months of energy and water bills, the waste contractor statement, the payroll export, the accident log. Most of the Basic Module comes from documents you already have.
Write B1 and B2 first. They are short text answers and they frame the rest.
Fill in the metrics. When a disclosure does not apply, say so and say why. A clear "not applicable, we have no permit-based emissions" is better than a blank.
Calculate and check. Totals, shares and ratios. Keep a note of each source document so you can answer follow-up questions.

Worked example

An illustrative company with made-up numbers: a joinery with 24 employees and a turnover of 3.2 million euro.

Electricity 120 MWh, of which 48 MWh from a green contract; natural gas 180 MWh. Total energy 300 MWh. Renewable share: 48 / 300 = 16%.
Scope 1 emissions 33 tCO2e, scope 2 emissions 25 tCO2e (from your carbon calculator or supplier). Total 58 tCO2e. GHG intensity: 58 / 3.2 = 18.1 tCO2e per million euro turnover.
Waste 40 tonnes, of which 30 tonnes recycled or reused. Diverted from disposal: 30 / 40 = 75%.
Employees: 24 at year end, 3 leavers. A simple turnover rate is 3 / 24 = 12.5%. Check the exact formula the standard uses before you publish.

Copyable template

Paste this into a document and replace the brackets.

B1 Basis for preparation
Company: [name], [legal form], [NACE sector code]
Employees (headcount at year end): [n]   Turnover: [EUR]
Sites: [list with country]   Reporting period: [start] to [end]
Module used: Basic Module

B2 Practices and policies
We have practices or policies on: [climate / pollution / water / biodiversity / resources / own workforce / business conduct]
Planned in the next year: [one or two sentences]

B3 Energy and GHG
Electricity: [MWh] (renewable: [MWh])   Fuels: [MWh]
Scope 1: [tCO2e]   Scope 2: [tCO2e]   Intensity: [tCO2e per EUR million]

B4 Pollution: [figures or "not applicable because ..."]
B5 Biodiversity: [sites in or near sensitive areas: yes/no, details]
B6 Water withdrawal: [m3]
B7 Waste: total [t], hazardous [t], recycled or reused [t]
B8 Workforce: [n] employees, [permanent/temporary], [by gender], leavers [n]
B9 Health and safety: recordable accidents [n], fatalities [n]
B10 Pay and training: [pay gap inputs], collective agreement coverage [%], training hours per employee [h]
B11 Corruption: convictions [n], fines [EUR]

Common mistakes

Mixing units: kWh on one bill, MWh on another. Convert everything before you add up.
Leaving a disclosure blank instead of explaining why it does not apply.
Using a different period for energy and for payroll.
Copying a number from last year without a source document.

Wondering whether you need to report at all? Read VSME vs CSRD. Got a questionnaire from your bank? See how to answer it with a VSME report.

Related guides

Sources

This guide explains the rules in plain language. It is not legal advice. Check your own country's law and, when in doubt, ask a qualified adviser.