The European Financial Reporting Advisory Group (EFRAG) is currently developing standards for sustainability reporting by small and medium-sized enterprises on behalf of the EU. EFRAG published the first drafts at the end of January 2024. A distinction is made here between mandatory LSME- and voluntary VSME- Sustainability reports. In contrast to the CSRD reporting obligation For large companies, the new LSME and VSME reports are to make the sustainability reporting requirements for SMEs easier.
LSME sustainability reports
Accordingly capital market-oriented SMEs ("Listed Small and Medium-sized Enterprises") whose securities are traded in the EU, from 2028 at the latest the dutytheir ESG impact in a public LSME report to explain. This would currently affect around 1,100 companies in Europe, including around 100 in Germany. The simplified structure of the LSME sustainability reports initially provides for general ESG disclosures, requirements, principles, measures and targets and requires the company's corresponding key figures. Some disclosure requirements are also not as strict as in the CSRD reports.
VSME sustainability reports
VSME reports ("Voluntary Small and Medium-sized Enterprises"), on the other hand, are voluntary. You should not capital market oriented enable SMEs to document their sustainability goals and projects more easily. In practice, small and medium-sized suppliers are increasingly being asked to do this by their suppliers. Clients, Stakeholders or Lenders is required. Companies subject to CSRD reporting requirements are already increasingly sending individual questionnaires to their suppliers, putting them under pressure. A VSME standard could help to reduce the indirect burden on SMEs in these areas.
The elaboration should remain practicable for SMEs
In developing the standards, EFRAG attaches particular importance to a Simple design of sustainability reports. It attempts to take all aspects of micro, small and medium-sized enterprises into account. On the one hand, the reports must cover the information requirements of the business partners and financial institutions subject to the reporting obligation and, on the other hand, the effort involved in obtaining information for SMEs must not get out of hand. Only if both conditions are met will the future LSME and VSME sustainability reports be a successful model for both sides.
Planned content of the LSME and VSME sustainability reports
The planned content for the LSME reports are mainly based on the requirements of the CSRD accounting guidelines. The reports must contain information that discloses the material impacts, opportunities and risks relating to environmental, social and sustainable aspects of corporate governance. The draft is divided into a simplified structure and consists of three main sections: "General requirements", "General information" and "Principles, measures and objectives". In addition, there are three further sections dealing with environmental, social and corporate practice indicators.
With VSME Reports EFRAG is planning a modular structure. They are to be prepared annually and can be integrated as a separate section in the (Group) management report under certain conditions. Otherwise, separate publication is planned. It should be available at the same time as the annual/group financial statements or financial reporting, if these are required. The company may omit certain confidential information. From the second year onwards, comparative figures for the previous year must be included in the report. There is a Basic modulewhich must be included in all VSME sustainability reports and covers around 30 data points, as well as two additional optional modules that can be supplemented variably.
The PAT module (Policies, Actions, Targets) supplements the basic module for companies with already defined sustainability guidelines. A materiality analysis in accordance with the VSME draft standard is required to disclose material sustainability information. The module explains company policies, measures and targets and covers energy efficiency, greenhouse gas emissions, financial risks and social aspects.
The Business Partner Module (BP module) extends the disclosures to include further data for lenders, investors and business partners. A materiality analysis in accordance with the VSME draft standard is also required here. The company must provide around 35 data points and descriptions, including risk sectors, gender diversity and emissions reduction targets. Information on physical risks of climate change, waste, and compliance with international standards such as the UN Guiding Principles on Business and Human Rights is required, as well as information on processes for compliance with guidelines such as the OECD Guidelines for Multinational Enterprises and potential violations related to the company's own workforce. In addition, information on the use of family-related leave and the number of trainees must be provided.
Is a voluntary VSME sustainability report worthwhile?
Absolutely. It is advantageous to report voluntarily on non-financial aspects, as this can improve the Transparency and Credibility of a company is increased and a Promotes a positive image. By meeting the expectations regarding sustainability and social responsibility in accordance with the VSME standard, companies can achieve a Competitive advantage obtain and Better stakeholder relationships build. The introduction of this standard invests in sustainable corporate development, minimizes environmental and social risks, reduces costs and improves resource efficiency. In addition, by applying the standard, companies are well prepared for new legal requirements and ongoing regulatory developments.
What happens next?
Stakeholders have the opportunity to submit their comments on the drafts to EFRAG via online questionnaires until May 21, 2024. EFRAG will evaluate these comments and present a revised version of the drafts. The final versions are expected to be published in fall 2024.
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