{"id":4091,"date":"2026-07-14T09:12:26","date_gmt":"2026-07-14T09:12:26","guid":{"rendered":"https:\/\/zerovia.ch\/?p=4091"},"modified":"2026-07-14T09:12:29","modified_gmt":"2026-07-14T09:12:29","slug":"from-vsme-to-vs-standard","status":"publish","type":"post","link":"https:\/\/zerovia.ch\/en\/vom-vsme-zum-vs-standard\/","title":{"rendered":"From VSME to VS Standard: The voluntary standard that no one will be able to bypass in the future"},"content":{"rendered":"

What does sustainability mean for a Swiss SME?<\/h2>\n\n\n\n
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On July 3, 2026, the EU Commission adopted the voluntary sustainability standard as a delegated act. It looks harmless \u2013 \u201evoluntary.\u00bb In reality, it decides which ESG data an SME in the supply chain still has to provide. An analysis.<\/h6>\n\n\n\n

Those who have followed European ESG regulation since the first CSRD consultation have learned to distrust announcements and focus on the mechanics. July 3, 2026, was one of those days when the mechanics were more important than the headline. The EU Commission, with its delegated act C(2026) 5011 Final<\/em> adopts the voluntary sustainability standard for companies outside the scope of CSRD \u2013 the binding version of what has so far been circulating the market as the VSME recommendation. The abbreviation \u201eVS\u00bb (Voluntary Standard) has quickly become established in professional discussions. The real news is not in the title: a \u201evoluntary\u00bb standard becomes the binding upper limit for everything that large customers and banks may demand from smaller suppliers.<\/p>\n\n\n\n

That sounds like a technical detail. It's the reason why the VS will become more relevant for the mid-market in the next 18 months than the CSRD itself. <\/p>\n\n\n\n

1. Where the CSRD ends \u2013 and what Omnibus has changed about it<\/h3>\n\n\n\n
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The Corporate Sustainability Reporting Directive (CSRD)<\/strong> its original version was designed for around 50,000 companies in the EU. It requires an audited sustainability report according to the ESRS<\/strong> (European Sustainability Reporting Standards), including dual materiality analysis and external audit. This is challenging but manageable for a large, capital-market-oriented company. For the traditional medium-sized business, it was too much from the start.<\/p>\n\n\n\n

This is exactly where the Omnibus I Package<\/strong> The Commission proposed it on February 26, 2025; the corresponding amending directive was finally adopted in early 2026 and entered into force in the spring of 2026. Three interventions are crucial for small and medium-sized enterprises:<\/p>\n\n\n\n

First, the scope of application.<\/strong> The CSRD obligation now only applies to companies with more than 1,000 employees<\/strong> and<\/em> about 450 million EUR revenue<\/strong>. This dramatically reduces the number of companies subject to reporting requirements\u2014estimates suggest a reduction of about 80 %. The majority of small and medium-sized enterprises are thus formally exempt from this direct obligation.<\/p>\n\n\n\n

Secondly, the streamlining of the ESRS.<\/strong> The revised standards reduce the number of data points from approximately 1.073 to approximately 320<\/strong> (if material) \u2013 a decrease of more than 70 %, and for mandatory data points, more than 60 %. However, the dual materiality framework\u2014ESRS 1 and 2 as the mandatory framework and E1 (climate) as the data backbone\u2014remains in place. The CSRD will thus become simpler, but not substantially different.<\/p>\n\n\n\n

Third \u2013 and this is the real lever \u2013 the \u201eValue Chain Cap.\u00bb.<\/strong> A company subject to CSRD may require business partners to fewer than 1,000 employees<\/strong> No more sustainability information beyond the voluntary standard will be requested. A recommendation becomes a legal cap. The VS is no longer just an offer for SMEs - it is the legal limit of what can be demanded from them.<\/p>\n<\/div>\n<\/div>\n\n\n\n

Critically evaluated<\/strong><\/p>\n\n\n\n

The cap protects against mandatory data requests beyond the VS \u2013 not against voluntary ones. Large customers can still request more, and many SMEs will supply for commercial reasons. Banks also operate partly outside the value chain logic due to their own regulatory requirements. \u201eAll requirements met\u00bb is therefore more precise than \u201eall standardized requirements met.\u00bb.<\/p>\n\n\n\n

CSRD Obligation Ends \u2013 VS Standard Begins<\/h4>\n\n\n\n

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Mandatory
CSRD<\/strong>
1,000+ employees AND
450 million EUR in revenue <\/p>\n\n\n\n

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  • Full ESRS (~320 DP, if significant) <\/li>\n\n\n\n
  • Double materiality analysis <\/li>\n\n\n\n
  • External audit requirement (Assurance)<\/li>\n<\/ul>\n<\/div>\n\n\n\n
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    VOLUNTARY \u00b7 CAPPED
    VS-Standard (Based on: VSME)<\/strong>
    Less than 1,000 employees
    outside the scope of CSRD obligations<\/p>\n\n\n\n

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    • Base Module B1\u2013B11 (Core KPIs)<\/li>\n\n\n\n
    • Comprehensive C1\u2013C9 (on request)<\/li>\n\n\n\n
    • No mandatory materiality, no audit obligation<\/li>\n<\/ul>\n<\/div>\n<\/div>\n\n\n\n
      VALUE CHAIN CAP (Omnibus I)<\/h6>\n\n\n\n

      A company subject to CSRD may not require SME suppliers to do anything beyond the EU standard (European Sustainability Reporting Standards).<\/p>\n\n\n\n

      Fig. 1 \u2014 Delimitation CSRD \u2194 VS Standard. The Value Chain Cap makes the voluntary standard a binding upper limit for data requests along the supply chain.<\/sub><\/p>\n\n\n\n

      2. From VSME to VS: The Development of a \u201eVoluntary\u00bb Standard with Teeth<\/h3>\n\n\n\n

      The VS doesn't fall from the sky. Its history explains why it is so effective. EFRAG had the VSME<\/strong> \u2013 the \u201eVoluntary Sustainability Reporting Standard for non-listed SMEs\u00bb \u2013 in December 2024<\/strong> Handed over to the Commission. It was the pragmatic answer to a real problem: SMEs were inundated by customers and banks with a proliferation of individual ESG questionnaires. The VSME was intended to curb this proliferation by one<\/em> replace standardized information.<\/p>\n\n\n\n

      In the July 2025<\/strong> did the Commission take over the VSME as Recommendation<\/strong>. An \nrecommendation in EU law is \u201esoft law\u00bb \u2014 non-binding. That is precisely what changed with Omnibus. The VSME went from being good advice to a legally enshrined reference point for the Value Chain Cap. And with the delegated act of July 3, 2026<\/strong> Does this version now have binding legal force as a delegated regulation \u2013 no longer advice, but applicable law.<\/p>\n\n\n\n

      The content structure of the VSME remains largely the same: a\u00a0Foundation Module (B1\u2013B11)<\/strong>\u00a0with the core key figures most frequently requested by value chain partners \u2013 including\u00a0Scope 1 and 2 GHG emissions<\/strong>, key figures on your own workforce, energy, and anti-corruption. Building on this, a\u00a0Comprehensive Module (C1\u2013C9)<\/strong>\u00a0for the additional information that banks, investors, and major clients typically require on top of that. The basic module is a prerequisite for the comprehensive module.<\/p>\n\n\n\n

      The VS is not a \u201enew\u00bb standard, but rather the VSME with legal teeth. Substantially, the disclosures hardly change; what changes is the legal status (recommendation \u2192 delegated regulation) and the function (template \u2192 statutory data limit). Those who understand this will position themselves correctly in the market sooner.<\/p>\n\n\n\n

      The essential differences: VSME (2024\/25) \u2192 VS (2026)
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