EFRAG VSME Template Guide: What UK SMEs Need to Know

You have received a questionnaire from a customer and it references something called the "VSME template." The acronyms mean nothing to you. The document looks dense. You need to respond by the end of the month.

This guide explains what the EFRAG VSME template actually is, what it asks for, and how UK SMEs can use it to handle ESG questionnaire responses more efficiently.

What is EFRAG?

EFRAG -- the European Financial Reporting Advisory Group -- is the body that develops sustainability reporting standards for the European Union. It created the European Sustainability Reporting Standards (ESRS) that large companies must follow when reporting under the Corporate Sustainability Reporting Directive (CSRD). The standard most relevant to SME suppliers is the VSME standard, which sets a ceiling on what large companies can ask of you.

EFRAG is not a regulator. It writes the standards. The European Commission adopts them into law. Think of EFRAG as the technical author behind the rules that large EU companies now follow.

Why this matters to UK businesses: the standards EFRAG writes determine what data your EU customers need to collect -- and therefore what they ask you for.

What is the VSME template?

VSME stands for Voluntary Sustainability Reporting Standard for non-listed Small- and Medium-Sized Enterprises. EFRAG published the VSME template to solve a specific problem.

Large companies reporting under CSRD need sustainability data from their supply chains. Without a common framework, every company designed its own questionnaire. SME suppliers ended up answering dozens of overlapping requests, each formatted differently, each asking for the same information in slightly different ways.

The VSME template sets a ceiling. It defines the maximum sustainability data that a large reporting company should reasonably request from an SME supplier. Following the February 2025 Omnibus simplification package, the European Commission reinforced this: VSME-aligned requests represent the upper bound of what SMEs should be asked to provide.

The template is voluntary for SMEs. No UK law requires you to use it. But when your customer structures their questionnaire around it, understanding the template makes your response faster and more accurate.

Who is the VSME template designed for?

The VSME reporting template targets SMEs that are part of the supply chain of larger reporting companies. In practical terms, this means your business if:

• You supply goods or services to an EU-headquartered company, or to a UK company with EU operations
• Your customers are subject to CSRD reporting obligations
• You have received questionnaires referencing "VSME," "ESRS value chain," or "supply chain sustainability data"

It is not designed for large enterprises (they report under the full ESRS) or for micro-enterprises with minimal supply chain exposure. It sits in the middle ground: structured enough to be useful, light enough for a finance director or operations manager to complete without specialist consultants.

If you are a UK SME with 10 to 250 employees and your customer base includes any EU-connected companies, the VSME template is likely heading your way -- if it has not arrived already.

Key sections and datapoints in the VSME template

The final VSME standard (published by EFRAG on 17 December 2024) is organised into two modules — the Basic Module and the Comprehensive Module. (Earlier drafts proposed three modules; the final standard consolidated to two.) Many supplier questionnaires draw mainly from the Basic Module. Reporting against the Basic Module is a prerequisite for the Comprehensive Module.

Basic Module

This is the minimum dataset and the entry point for all SMEs. It comprises 11 disclosures (B1–B11) covering the core sustainability data most often requested by value chain partners, much of which SMEs already track somewhere in the business:

• Energy consumption -- total annual energy use in kWh, broken down by source where possible (electricity, gas, fuel)
• Greenhouse gas emissions -- Scope 1 (direct, e.g. gas heating, company vehicles) and Scope 2 (indirect, e.g. purchased electricity), measured in tonnes CO2e
• Pollution, water, biodiversity, and resource use / circular economy basics
• Workforce headcount and characteristics -- total employees, gender split, contract types
• Health and safety, and remuneration -- work-related incidents and basic pay data
• Key policies -- whether you have written policies for environment, health and safety, anti-corruption, and data protection (yes/no, with dates)
• Corruption and bribery -- any convictions and fines

If you can pull together your energy bills, HR records, and policy documents, you can complete the Basic Module. No specialist tools required.

Comprehensive Module

This builds on the Basic Module and adds 9 further disclosures (C1–C9) — the additional detail that banks, investors, and value chain partners more often need. Where the Basic Module asks "what are the numbers," the Comprehensive Module asks "what are you doing about it" and adds further quantitative depth:

• Business model, strategy, and sustainability practices -- what you do, where, and how sustainability connects to your operations and future initiatives
• GHG reduction targets and any climate transition plan
• Climate risks and how you manage them
• Additional workforce metrics -- such as the gender pay gap and human rights matters
• Confirmed value chain incidents relating to human rights
• Exclusion from EU reference benchmarks, and revenue/exposure data a customer may need for their own reporting

This is where two SMEs in the same sector can look very different. A manufacturer and a professional services firm will have entirely different material topics, risks, and actions. That is expected. Most UK SMEs will not be asked for the full Comprehensive Module in initial questionnaires — customers typically start with the Basic Module and request additional Comprehensive disclosures only where their specific reporting requires it.

How UK SMEs can use the VSME template alongside questionnaire responses

The VSME template is not just something you react to when a questionnaire arrives. Used proactively, it becomes a framework for organising all of your ESG data.

Map your existing data to VSME categories. Take the facts, figures, and policies you already have and slot them into the Basic Module and Comprehensive Module structure. This gives you a clear picture of what you can already answer and where the gaps are.

Build a reusable fact library. Each VSME datapoint -- your Scope 2 emissions figure, your health and safety incident rate, your policy review date -- becomes a standalone fact you can reuse across every questionnaire. When customers use VSME-aligned formats, the same facts apply directly. When they use their own format, the underlying data is still the same. Our guide on why UK SMEs need better ESG questionnaire management covers the broader case for this approach.

Identify gaps before you are asked. If you can fill in the Basic Module today but have nothing for the Comprehensive Module, you know where to focus. The VSME data checklist tracks the Basic Module's 11 disclosures and shows exactly where your gaps are. The ESG readiness checker gives a broader view across all four ESG pillars. Doing this proactively -- before the next questionnaire arrives -- turns a scramble into a 30-minute exercise.

Estimate the time commitment. If you are unsure how much time VSME-aligned questionnaires will take, the ESG time calculator gives you a realistic estimate based on your company size and the number of questionnaires you handle.

The connection to CSRD

VSME does not exist in isolation. It is a direct product of CSRD implementation.

Large EU companies reporting under CSRD must disclose value chain sustainability data. That requirement creates a downstream data demand on their suppliers -- including UK SMEs. The VSME template is the mechanism that standardises and limits those demands.

The February 2025 Omnibus changes reinforced this connection by establishing VSME as the maximum that reporting companies can ask from SME suppliers. This means questionnaires should become more predictable and bounded. The same categories. The same types of datapoints. The same evidence requirements.

For a detailed breakdown of who reports under CSRD and how the thresholds work, see the CSRD thresholds guide linked in the introduction above.

How AnswerVault helps

AnswerVault helps UK SMEs for exactly this workflow. You will create a vault of reusable facts organised across the same categories the VSME template covers: environment, social, governance, supply chain, and company overview.

When a VSME-aligned questionnaire arrives, the TF-IDF suggestion engine will match each question to your stored facts -- across 65 ESG synonym groups -- so you will be selecting and refining answers rather than writing from scratch. Evidence documents will attach directly to facts, so certificates, policies, and data reports will be one click away.

The result: what used to take days takes hours. What used to be inconsistent becomes standardised. And when the next questionnaire arrives in a different format, your facts still apply because the underlying VSME datapoints have not changed.

Try AnswerVault free to build your VSME-aligned fact library before the next questionnaire lands.

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This article provides general guidance for UK SMEs working with the EFRAG VSME standard. It is not legal or regulatory advice. The VSME standard was finalised by EFRAG in December 2024, but applicability and the supply-chain ceiling provision in the Omnibus package continue to be clarified through EFRAG guidance and delegated acts. Specific application to your reporting obligations should be reviewed with your sustainability or legal advisor; EFRAG's published VSME text (efrag.org) is the definitive reference.