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VSME vs CSRD: which one applies to you?

The difference between the CSRD (with the ESRS) and the Voluntary Standard (VS, formerly VSME) after the Omnibus I changes, who falls under each, and what a small supplier should prepare.

Last updated: 2026-10-26 · 2 min read

Many small companies search "VSME vs CSRD" after a customer or bank asks for sustainability data. The short answer: the CSRD is a legal reporting obligation for the largest companies, and the Voluntary Standard (VS, formerly VSME) is the simplified standard for everyone else.

The CSRD: an obligation for large companies

The Corporate Sustainability Reporting Directive (CSRD) requires companies in scope to publish a sustainability report under the European Sustainability Reporting Standards (ESRS).

The Omnibus I Directive, Directive (EU) 2026/470, narrowed that scope considerably. It was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. An EU company is now in scope only if it exceeds both:

  • 1,000 employees on average during the financial year, and
  • €450 million net turnover.

Member states must bring the changes into national law by 19 March 2027, so check your country's status.

The Voluntary Standard: for companies outside the CSRD

The Voluntary Standard was adopted as Commission Delegated Regulation (EU) 2026/1560, published on 21 September 2026. Nobody is obliged to use it. It gives companies outside the CSRD one standard answer to the sustainability questions they receive from customers, banks and tenders. See What is the Voluntary Standard?

Side by side

CSRD (ESRS)Voluntary Standard (VS)
Legal statusObligation for companies in scopeVoluntary
WhoMore than 1,000 employees and more than €450 million turnoverCompanies outside the CSRD, including micro-undertakings
ContentFull ESRS sustainability statementBasic Module (B1–B11), optional Comprehensive Module (C1–C9)
Why you would prepare itThe law requires itCustomers, banks and tenders ask for the data

Where the two meet: the value chain cap

A CSRD-reporting customer needs data from its suppliers. From financial years beginning on or after 1 January 2027, it may not require suppliers with up to 1,000 employees to provide more for its CSRD report than the Voluntary Standard specifies. Your VS report is therefore the natural answer to a CSRD customer. See the value chain cap.

What to do

  1. Check your size. If you have 1,000 employees or fewer, the CSRD does not apply to you and the Voluntary Standard is the relevant reference.
  2. Prepare the Basic Module once, with the free VS Report Builder.
  3. Reuse it for every customer and bank request, and answer extra questions as described in How to answer a sustainability questionnaire.

Sources: Directive (EU) 2026/470 (Omnibus I), as summarised by Linklaters, 26 February 2026; Commission Delegated Regulation (EU) 2026/1560 (EUR-Lex). General information, not legal advice.