How VSME OS reports satisfy the requirements of CSRD, GHG Protocol, ISO 14064-1:2018, Commission Recommendation (EU) 2025/1710 (EU VSME) and the EU Voluntary Standard adopted on 3 July 2026 — and what remains the buyer's responsibility.
CSRD ESRS E1
AlignedScope 1, 2 (location & market), Scope 3 Cat. 6+7, intensity metric
GHG Protocol
AlignedActivity-based method, operational control boundary, Scope 2 dual reporting
ISO 14064-1:2018
AlignedQuantification, boundary statement, uncertainty disclosure, attestation
EU VSME (2025/1710)
AlignedSME-appropriate data points, proportionality principle, limited assurance
EU Voluntary Standard
AlignedDelegated regulation adopted 3 July 2026 — the value chain cap ceiling. Built from VSME with minimal change. Adopted by the Commission on 3 July 2026. The two-month European Parliament and Council scrutiny period closed on 4 September 2026 with no objection from either institution. It has not yet been published in the Official Journal, so it is not yet in force and does not yet carry an OJ number. Expected to apply from financial year 2027.
SBTi SME Pathway
CompatibleScope 1+2 data directly usable for SBTi target-setting baseline
CDP Supply Chain
CompatibleScope totals and intensity metric match CDP S3.1 supplier fields
EU Taxonomy
PartialProvides GHG data for Do No Significant Harm climate assessment; full taxonomy requires additional disclosures
Ecovadis / Sedex
CompatibleCarbon footprint data can be imported into Ecovadis environmental scorecards
The EU Omnibus I Directive (published 26 February 2026, in force 18 March 2026) significantly revised the CSRD. Companies with more than 1,000 employees and over €450 million net turnover are required to disclose Scope 1, 2, and Scope 3 emissions, with first reports for the second wave covering financial year 2027 and published in 2028. Roughly 90% of the companies previously captured fall out of scope.
Omnibus I introduced a value chain cap: a large reporting company may not require a company with fewer than 1,000 employees to provide more sustainability information than the EU voluntary standard specifies. The Commission adopted that standard as a delegated regulation on 3 July 2026, and the European Parliament and Council scrutiny period closed on 4 September 2026 with no objection. It enters into force on publication in the Official Journal, which has not happened yet, and is expected to apply from financial year 2027. Until it is published the reference point remains Commission Recommendation (EU) 2025/1710 (VSME), which the delegated regulation was built from with minimal change.
That cap is what VSME OS is built around. A supplier declaration produced here contains the scopes, the intensity metric, the boundary statement and the attestation that the voluntary standard describes — and stops there. It is designed to be sufficient for a buyer's value chain data request, and it is not an independently assured report.
Under ESRS E1, large companies must disclose:
E1-6 — Gross Scope 1, 2, 3 GHG emissions (in tCO₂e)
Page 1 totals panel — all three scopes in tCO₂e
E1-6 — Scope 2 location-based AND market-based
Location-based only. All electricity, including electricity bought under a renewable contract, at the country grid average — the figure the VSME standard asks for. Market-based dual reporting is not yet implemented.
E1-6 — GHG intensity of net revenues
Two intensity metrics: kgCO₂e / M revenue currency (ESRS E1-6 compliant) and kgCO₂e / actual EUR (4 decimal places). Both shown on Page 1.
E1-6 — Emission factor sources disclosed
Primary database named per country. Scope 3 RF multiplier disclosed. Factor versions noted in footer.
E1-6 — Boundary statement and exclusions
Page 4 Section 5 lists every assessed but zero-activity source, grouped by scope (Scope 1 / 2 / 3)
E1-6 — Upstream Scope 3 Cat. 1 (purchased goods)
Not yet covered — on the roadmap
E1-5 — Transition plan and targets
Outside scope of VSME OS (measurement tool, not target-setting tool)
How data flows from SME supplier to CSRD filing:
SME supplier enters emissions data in VSME OS
Scope 1, 2, 3 activity data
VSME OS generates PDF declaration (GHG Protocol-based)
4-page: Summary · Breakdown · Declaration · Methodology
Supplier shares PDF with buying company
Via email, buyer portal, or procurement platform
Buyer ingests Scope 3 tCO₂e from Page 1
Into their Scope 3 Cat. 1 or Cat. 11 inventory
Buyer discloses aggregated Scope 3 in CSRD filing
Under ESRS E1-6, with supplier data as evidence base
The GHG Protocol Corporate Standard (WRI / WBCSD, 2004, updated 2015 for Scope 2) is the most widely used international framework for corporate GHG accounting and reporting. It defines Scopes 1, 2, and 3, the activity-based calculation methodology, and the requirements for boundary setting and disclosure.
Relevance
All material emission sources for a typical SME are included. Sources not yet covered are explicitly disclosed as boundary exclusions.
Completeness
All Scope 1, 2, and selected Scope 3 sources within the declared boundary are covered. Boundary is defined using the operational control approach.
Consistency
The same methodology, factors, and boundary apply across reporting years, enabling year-on-year comparison.
Transparency
Factor sources, update dates, assumptions (e.g. RF×1.9 for flights), and boundary exclusions are all disclosed on-report.
Accuracy
Country-specific emission factors from national authoritative databases. Self-attested (limited assurance) — disclosure is on-report.
The 2015 update to the GHG Protocol asks for Scope 2 emissions on both the location-based and the market-based method where a market-based figure exists. VSME OS currently reports location-based only, and labels it as such everywhere it appears:
The location-based figure is the one the EU VSME standard asks for at §33(b), and the one a buyer needs for their own Scope 3 Category 3 calculation. A supplier who holds a renewable contract still discloses that contract: the renewable share of energy consumption appears in the §32 energy table.
ISO 14064-1:2018 specifies principles and requirements for the quantification and reporting of GHG emissions at the organisation level. It is the international standard underlying the GHG Protocol and is referenced by CSRD as an acceptable quantification methodology.
| ISO 14064-1 Requirement | VSME OS Implementation |
|---|---|
| Organisational boundary (Clause 5.2) | Operational control approach. Declared in report boundary statement. |
| GHG sources and sinks (Clause 5.3) | All relevant emission sources categorised by scope and type. Exclusions documented. |
| Activity data (Clause 6.2) | Supplier-entered data with evidence documentation listed in Declaration. |
| Emission factors (Clause 6.3) | Country-specific, annually updated, source-cited in every report. |
| GHG assertion (Clause 7) | Page 1 totals panel. Scope-level breakdown on Page 2. |
| Uncertainty assessment (Clause 6.5) | Disclosed as self-attested (limited assurance) in disclaimer. |
| GHG report contents (Clause 7.2) | All required elements present across 4 pages: summary, activity detail, declaration, and methodology & audit trail. |
The European Commission published the Voluntary Sustainability Reporting Standard for SMEs (VSME) as Commission Recommendation (EU) 2025/1710, signed in Brussels on 30 July 2025. It was designed to let smaller companies report sustainability data proportionately — without the full burden of ESRS — while still producing data their buyers can use for CSRD disclosures.
Update — 3 July 2026
The Commission adopted two delegated regulations on 3 July 2026. The first revises the ESRS, cutting mandatory datapoints by roughly 61%. The second supplements Directive 2013/34/EU and establishes the EU Voluntary Standard — the reporting standard for undertakings protected by the value chain cap.
This is the material change for suppliers. The ceiling on what a large buyer may demand moves from a Commission Recommendation to a binding delegated regulation. The reporting stays voluntary; the limit on the requestbecomes law. The Commission's stated approach was to keep changes to VSME to a minimum, made primarily to realign it with the revised ESRS — so the standard this platform was built around did not move underneath it.
Legal status today: Adopted by the Commission on 3 July 2026. The two-month European Parliament and Council scrutiny period closed on 4 September 2026 with no objection from either institution. It has not yet been published in the Official Journal, so it is not yet in force and does not yet carry an OJ number. Expected to apply from financial year 2027. Until it enters into force, Commission Recommendation (EU) 2025/1710 remains the operative reference. We do not describe either instrument as in force before it is.
Regulatory position verified 2026-09-07. Full references: Commission Recommendation (EU) 2025/1710 of 30 July 2025 — voluntary sustainability reporting standard for non-listed SMEs (VSME); Commission Delegated Regulation of 3 July 2026 supplementing Directive 2013/34/EU — sustainability reporting standard for voluntary use by undertakings protected by the value chain cap ("the Voluntary Standard"); Commission Delegated Regulation of 3 July 2026 amending Delegated Regulation (EU) 2023/2772 — revised European Sustainability Reporting Standards.
VSME OS is named after and built around this standard. The key principles reflected in the platform:
Proportionality
Data entry is limited to sources that are material for the majority of SMEs. Highly technical or data-intensive sources (e.g. Scope 3 Cat. 1 purchased goods) are deferred to a later release to avoid overwhelming small companies on first engagement.
Interoperability
Report format designed to be directly usable by buyers for ESRS E1 Scope 3 disclosures without reformatting. The tCO₂e figures map directly to ESRS E1-6 disclosure fields.
Reliability
Country-specific emission factors from authoritative national databases, not generic global averages. Factor sources and update dates cited on every report.
Accessibility
Plain-language tooltips and "how to find this number" guidance on every data entry field, designed for SMEs without a sustainability team.
Important — please read before using supplier data in CSRD filings.
VSME OS supplier reports satisfy the data collectionrequirement for Scope 3. They do not remove the buyer's obligation to:
We can walk your sustainability or legal team through how VSME OS data integrates with your CSRD reporting workflow.