The VSME explained for Swiss SMEs
What the European sustainability reporting standard for SMEs is, what changed in 2026, what customers can ask you for, and what Swiss law says.
Updated 29 October 2026The VSME in brief
The VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs) is a sustainability reporting standard designed for small and medium-sized enterprises. It was developed by EFRAG, the body that advises the European Commission on reporting standards, and published in December 2024.
Its purpose is simple: to replace the many questionnaires SMEs receive from customers, banks and investors with a single report in a common format. It has two modules:
- the Basic module, with eleven disclosures numbered B1 to B11: the minimum, and the target for the smallest companies;
- the optional Comprehensive module, with nine additional disclosures (C1 to C9) often requested by banks and large customers.
On 30 July 2025, the European Commission recommended it to SMEs that wish to report sustainability information.
2026: the VSME becomes the EU voluntary standard
Two European acts changed the picture in 2026:
- The Omnibus I Directive (EU) 2026/470, published in the Official Journal on 26 February 2026, sharply narrows the scope of the CSRD: only companies with more than 1,000 employees and more than EUR 450 million in turnover remain subject to mandatory reporting.
- Delegated Regulation (EU) 2026/1560, adopted on 3 July 2026 and published in the Official Journal on 21 September 2026, makes the VSME the EU's official voluntary standard. Changes from EFRAG's text are limited: the Basic and Comprehensive modules and the numbering of disclosures are retained.
In the 2026 version, some environmental data points become optional for companies with 10 employees or fewer.
What customers can ask you for
This is the key point for an SME. The Omnibus I Directive introduces a value-chain cap: a company subject to the CSRD may not require, for its own sustainability report, information beyond the voluntary standard from companies in its value chain with no more than 1,000 employees. Those companies may decline requests that exceed the cap, and the requesting company must inform them of this.
The cap applies to financial years beginning on or after 1 January 2027. It has two limits worth knowing:
- it only covers requests made for the customer's sustainability report: bank questionnaires, tender criteria and information required by other laws are not affected;
- it is a ceiling, not an obligation: no SME is required to publish a report.
And for a Swiss SME?
EU law does not apply directly to a Swiss SME. But many Swiss SMEs supply European companies, or Swiss groups that publish their own sustainability report. These customers will align their supplier questionnaires with the voluntary standard, since it is the common basis recognised in the EU.
A report in the Basic module format therefore lets you answer most requests with a single document, updated once a year, instead of filling in a different questionnaire for each customer.
The Basic module, disclosure by disclosure
What each disclosure covers, and where to find the information in a Swiss company.
| Code | What to report | Where to find it in Switzerland |
|---|---|---|
| B1 | Basis for preparation: module chosen, individual or consolidated report, legal form, NACE activity code, turnover, balance sheet total, headcount, countries and sites, certifications. | Commercial register (Zefix), annual accounts, AHV/AVS statement, FSO NOGA code. |
| B2 | Practices, policies and initiatives for the transition to a more sustainable economy, by topic, and whether they are public. | Internal regulations, target agreements with EnAW or act. |
| B3 | Energy consumed and renewable share, scope 1 and 2 greenhouse gas emissions, intensity relative to turnover. | Energy bills, electricity disclosure or Pronovo guarantees of origin, FOEN and KBOB factors. |
| B4 | Pollutant emissions to air, water and soil, where the company must already report them. | Permits and inspections under the air and water protection ordinances. |
| B5 | Number and area of sites in or near biodiversity-sensitive areas. Optional: total, sealed and nature-oriented areas. | Federal inventories on map.geo.admin.ch, land register. |
| B6 | Total water withdrawal, of which in water-stressed areas, and process consumption where relevant. | Water utility bills. |
| B7 | Circular economy principles, waste by type (non-hazardous and hazardous), share recycled or reused, significant material flows. | Waste contractor slips, tracking documents for special waste. |
| B8 | Headcount by contract type, gender and country, turnover rate from 50 employees. | Staff statistics, AHV/AVS statement. |
| B9 | Number and rate of work-related accidents, fatalities. | Reports to the accident insurer (Suva or other). |
| B10 | Compliance with applicable minimum wages, gender pay gap, collective agreement coverage, training hours by gender. | Applicable collective agreement, cantonal minimum wages, equal pay analysis (Gender Equality Act). |
| B11 | Convictions and fines for corruption and bribery. | Management. |
The Tilka assessment covers these eleven disclosures using Swiss terms, calculates totals and emissions, and flags what is missing.
What Swiss law says
In Switzerland, the duty to report on non-financial matters (Art. 964a et seq. of the Code of Obligations) only applies to large public-interest companies, in particular listed companies and FINMA-supervised institutions which, together with the companies they control, have at least 500 full-time positions on annual average and exceed CHF 20 million in total assets or CHF 40 million in turnover. Since 1 January 2024, an ordinance specifies what these companies must report on climate matters.
On 2 April 2026, the Federal Council opened a consultation on an indirect counter-proposal to the new responsible business initiative. Under this draft, fewer companies would have to report than today: around 100 instead of around 200. Parliament still has to decide.
For a Swiss SME, there is therefore no legal duty to publish a sustainability report. It is customers, banks and tenders that ask for one.
FAQ
Is the VSME mandatory for Swiss SMEs?
No. It is a voluntary standard, and EU law does not apply directly to Swiss companies. Its value is commercial: answering customers and your bank in a format they recognise.
How does it differ from the CSRD and the ESRS?
The CSRD is the directive that requires very large EU companies to report under detailed standards called the ESRS. The VSME is the simplified, voluntary version designed for SMEs.
Is the Basic module enough?
For most customer requests, yes. Some banks also ask for parts of the Comprehensive module, for example on climate risks.
Does the report need an audit?
No, it is not required. If a customer wants reliable figures, a document-based verification is often enough. For formal assurance, you need a licensed auditor.
Sources
- EFRAG, VSME digital template and XBRL taxonomy
- European Commission, VSME recommendation (July 2025)
- Delegated Regulation (EU) 2026/1560, EUR-Lex
- Linklaters, Omnibus I Directive published in the Official Journal (February 2026)
- SRF, Federal Council counter-proposal on corporate responsibility (2 April 2026)
- Fedlex, Swiss Code of Obligations (Art. 964a et seq.)
This guide is general information and not legal advice. Tilka is not affiliated with EFRAG or the European Commission.
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