The Voluntary Standard (VS) it replaces the previous VSME as the EU reference standard for voluntary sustainability reporting. With Delegated Regulation (EU) 2026/1560 of 24 September 2026, it receives a binding legal basis and at the same time lays down the Value Chain Cap fixed. This is an upper limit for certain sustainability information that companies required to report under the CSRD may require from smaller companies in their value chain. However, the use of the VS standard itself remains voluntary, as does VSME.
The most important thing in brief
- Legal basis: Delegated Regulation (EU) 2026/1560 of 3 July 2026, published in the EU Official Journal on 21 September 2026, entered into force on 24 September 2026.
- Application scope: All companies with up to 1,000 employees, regardless of whether they are listed on a stock exchange. The VSME applied to non-listed SMEs with up to 250 employees.
- Voluntary: The use of VS remains voluntary.
- New: The Value Chain Cap limits the information that reportable companies may request from their value chain. It applies to fiscal years that begin on or after January 1, 2027.
- In terms of content: The data points are grouped according to company size. The greenhouse gas intensity has been reduced, and the biodiversity data have been reduced.
What is the Voluntary Standard?
The VS is a voluntary reporting standard for companies that are not subject to the reporting obligation of the Corporate Sustainability Reporting Directive (CSRD). It is based on the European Financial Reporting Advisory Group's (EFRAG) standards for SME sustainability reporting. While listed SMEs (“Listed Small and Medium-sized Enterprises”) will, from 2028, have the obligation to present their ESG impacts in an LSME report made public, the VS builds on the VSME standards. The EU Commission published these as a recommendation (EU) 2025/1710 in July 2025 for “Voluntary Small and Medium-sized Enterprises” and has been developing them ever since.
Find out more in our article LSME and VSME sustainability reports for SMEs.
The new Voluntary Standard thus fulfills two tasks:
- It provides companies with a uniform framework for disclosing sustainability information to banks, investors, and business partners.
- It sets the upper limit for information requests from the value chain (Annex 2 of the Regulation).
Why was VSME transformed into VS?
The triggers are the new ones CSRD thresholds & CSDDD changes due to EU omnibus directive from the beginning of 2026. This omnibus I-package has indeed significantly restricted the scope of application of the CSRD. Since then, only companies with more than 1,000 employees and more than 450 million euros in net sales are now required to report. Many companies that had prepared for the CSRD are therefore no longer subject to reporting requirements.
They remain indirectly affected, however, because reporting companies and banks continue to request sustainability data from their suppliers and borrowers. The VSME was only a non-binding recommendation for this purpose. The VS is now the regulatory response to this gap. It defines what can be requested and protects companies with up to 1,000 employees from endless questionnaires.
The Value Chain Cap: What can business partners demand?
The Value Chain Cap is aimed at companies that are required to report under the CSRD. They may not require sustainability information from companies in their value chain that have an average of fewer than 1,000 employees for their CSRD reporting that goes beyond the VS.
Important for context:
- Only the upper limit is binding., Not the standard itself. A supplier does not have to create a VS report, but can use the VS as a benchmark.
- The VS knows two different upper limits, Depending on the size of the company. For small businesses with up to 10 employees, the amount of information is significantly smaller.
- The value chain cap regulations apply from business years that begin on or after January 1, 2027.
- Financial institutions are required to support the additional information they request from companies with up to 1,000 employees with the VS, wherever possible.
VSME and VS compared
| Feature | VSME | Voluntary Standard (VS) |
| Legal nature | Recommendation of the European Commission (EU) 2025/1710 | Delegated Regulation (EU) 2026/1560; reporting remains voluntary; the standard itself is EU law. |
| Target group | Unlisted SMEs with up to 250 employees | Companies outside the CSRD reporting obligation, explicitly up to 1,000 employees; stock market listing is not an exclusion criterion |
| Small businesses (under 10 employees) | Same information as other companies | Significantly more compact standard |
| Value chain | No binding upper limit for data queries | Value Chain Cap: Companies with a CSRD obligation may, in principle, only require VS information from companies with up to 1,000 employees; this will be decisive for fiscal years starting on January 1, 2027. |
| Scope | Comprehensive catalog | Significantly slimmer, about 30 pages instead of 66; some information has been omitted or simplified. |
| Structure | Basic and additional modules | Closer labeling: “necessary”, “necessary if applicable”, “voluntary” and “voluntary if sector-relevant”; differentiation based on company size, especially up to 10 employees. |
| Content | Among other things, GHG intensity as a mandatory field | GHG intensity is eliminated; biodiversity reporting is reduced; the gender pay gap is no longer mandatory by default. |
| Greenhouse gas intensity | contains | will be eliminated |
| Fluctuation | Basic module (B8) | Additional module (C5) |
| Guidelines | Part of the standard | No longer part of the regulation; not binding at the EFRAG Knowledge Hub |
How is the VS standard structured?
The VS consists of a Basic module and a Additional module. The basic module contains the basic information. The additional module supplements it with additional information and can only be used in addition to the basic module, never alone.
There are two rules for application:
- Completeness: Anyone who uses a module must implement its requirements in order to report in compliance with VS. Picking out individual details is not sufficient. VS now explicitly states this.
- “If applicable”: Data points only need to be reported if they are relevant to the company at all. For example, if someone does not have their own vehicles, they do not have to report their fuel consumption either. This principle has already been in effect in the VSME and remains in effect.
Both do not contradict each other: “If applicable,” determines which data points are relevant for a company. Completeness requires that it then report all of these relevant data points.
What does this mean for companies?
Anyone who has already reported to VSME: According to a report, the recommendation (EU) 2025/1710 is no longer legally valid since the entry into force of the EU. The VSME module is being further developed on the platform of the German Sustainability Code (DNK) until the end of 2026. Until then, VSME reports can still be created. Existing data will be automatically transferred thereafter, so only modified data points need to be revised. Published VSME reports remain available as PDFs.
For those who have not yet reported: The VS is a standardized framework for structured responses to inquiries from banks, investors, and clients. Depending on the size of the company, the effort can be significantly reduced.
Outlook: From 2027, a data interface (DNK Finance Bridge) will be created together with banks and banking associations, through which ESG data can be transferred to banking systems in a standardized format based on the VS standard.
Relevance for industry and commerce
For energy-intensive companies and businesses with their own production, a clean GHG report depends on a reliable data base regarding energy consumption and emissions. Who Photovoltaics and Battery storage when operating a system, these figures change: self-consumption, grid connection and load patterns are directly reflected in the energy data. Therefore, it is worth measuring and documenting the system properly right from the start of operation, not just when reporting.
Frequently asked questions about the Voluntary Standard
Is the Voluntary Standard mandatory?
No. The use of VS is voluntary. The upper limit for information requests (Value Chain Cap) is binding and must be observed by companies subject to the CSRD.
Who can report after the Voluntary Standard?
All companies with up to 1,000 employees, regardless of whether they are listed on the stock exchange.
When does the Voluntary Standard apply?
The regulation is in effect since September 24, 2026. The rules regarding the Value Chain Cap apply to business years that begin on or after January 1, 2027.
What is the Value Chain Cap?
The upper limit for sustainability information that companies subject to the CSRD reporting obligation may require from business partners in their value chain with fewer than 1,000 employees for their own reporting.
What happens to already created VSME reports?
Published VSME reports remain available as PDFs. DNK automatically transfers unfinished reports to the VS module after the switchover.
Does a VS report need to be externally reviewed?
No. The VS is designed for voluntary reporting and is not subject to mandatory review. Voluntary review is possible.