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A German client sends you an ESG questionnaire, a French client sends another one, and your bank adds a third: three formats, three platforms, and just as many evenings spent searching for figures. As of 2026, the European Union has set a clear limit, effective starting with the 2027 fiscal year: a client subject to the CSRD can no longer require a supplier with 1,000 employees or fewer to provide information that goes beyond the VSME standard. For a Swiss SME, this voluntary standard becomes both a single response format and a legal shield.
Here is what the VSME standard includes, what it actually covers, its limitations, and the steps you need to follow to prepare your report.
Why Your Swiss SME Is Receiving ESG Questionnaires from European Clients
Not subject to the CSRD, but still affected
The Federal Council’s report of November 5, 2025, drafted in response to the Dittli postulate, states the fact plainly. Swiss SMEs are rarely subject to European ESG regulations, but they must provide sustainability information to customers who are subject to these regulations. The CSRD and the German Supply Chain Act are the regulations that most frequently affect them.
Business customers are exerting the most pressure. The small and medium-sized enterprises surveyed for this report describe an enormous workload: entering the same data on the platforms of various private service providers, such as EcoVadis or IntegrityNext.
How many Swiss companies are affected? There are two official estimates:
- up to 50,000 companies, primarily SMEs, indirectly affected by the CSRD, the European due diligence requirement, the European Deforestation Regulation, and German law, according to the Dittli report (a survey conducted in late 2024 among 354 companies);
- between 100,000 and 120,000 companies, primarily SMEs, indirectly affected by European regulations, according to the impact assessment dated March 5, 2026, cited in the explanatory report accompanying the preliminary draft law on sustainable corporate governance.
The two studies were not conducted at the same time and did not use the same methodology. However, the order of magnitude alone is enough to make a decision: if you ship to European companies, this issue concerns you.
What the Omnibus Directive Changed in 2026
Directive (EU) 2026/470, known as Omnibus I, published in the Official Journal of the EU on February 26, 2026, significantly narrowed the scope of the CSRD. The explanatory report from the Federal Office of Justice summarizes the changes to the thresholds:
| Target Companies | Initial CSRD | CSRD after Omnibus I |
|---|---|---|
| European Companies | More than 250 employees and more than €50 million in revenue or more than €25 million in total assets, or publicly traded companies | More than 1,000 employees and more than €450 million in global net revenue |
| Non-European groups, including Swiss ones | At least €150 million in revenue in the EU | More than €450 million in net revenue in the EU and a subsidiary or branch in the EU with revenue of €200 million |
For you, the impact is twofold. The clients still subject to the CSRD are now very large conglomerates, with structured ESG teams and specific requirements. And the same directive has established protections for their suppliers: the value chain cap, for which the VSME standard serves as the benchmark. For details on the new thresholds and their impact on directly affected Swiss companies, see the article “New CSRD Version: What’s the Impact if I’m a Swiss Company?”
The VSME Standard Explained: What It Includes (and What It Doesn't)
From the EFRAG standard to Delegated Regulation (EU) 2026/1560
The VSME standard has changed status in less than two years:
- December 2024: EFRAG, the technical body that advises the European Commission, finalizes the VSME standard for unlisted SMEs.
- July 30, 2025: The European Commission recommends its use by micro, small, and medium-sized enterprises through Recommendation (EU) 2025/1710.
- February 26, 2026: The Omnibus I Directive provides for a voluntary standard adopted by delegated act and establishes it as the benchmark for the value chain cap.
- July 3, 2026: The Commission adopts Delegated Regulation (EU) 2026/1560.
- September 21, 2026: Publication in the Official Journal, with entry into force on September 24, 2026.
- Fiscal years beginning on or after January 1, 2027: Application of the value chain cap.
The official text now refers to a “voluntary standard.” In communications with clients, banks, and rating agencies, the term “VSME” remains the most common. Another significant change noted bythe Belgian Institute of Company Auditors is that the standard now applies to all companies with an average of 1,000 employees or fewer, rather than just SMEs. In Switzerland, where SECO and the FSO define an SME as any company with fewer than 250 employees, all SMEs therefore fall into this category.
Basic Module (B1–B11) and Comprehensive Module (C1–C9)
The VSME standard offers two options: Option A (base module only) and Option B (base module and full module). The full module is never used on its own. Here is what the base module specifically requires of you, according to the delegated regulation and the summary by the Garrigues firm:
| Indicator | What you actually provide |
|---|---|
| B1 Place of Business | Selected option, declaration of compliance, legal form, NACE code, balance sheet, number of employees, countries of operation, location of sites |
| B2 Practices and Policies | Description of sustainable transition practices, policies, and initiatives |
| B3 Energy and GHG | Total energy consumption in MWh (renewable and non-renewable), gross Scope 1 and 2 emissions in metric tons of CO₂ equivalent |
| B4 Pollution | Emissions of pollutants into the air, water, and soil—whether you are already required to report them or whether your environmental management system tracks them |
| B5 Biodiversity | Sites located in or near a biodiversity-sensitive area |
| B6 Water | Total water withdrawals, and consumption if your processes use a lot of water |
| B7 Circular Economy and Waste | Whether or not circular economy principles are applied; hazardous and non-hazardous waste; percentage recycled or reused |
| B8 Workforce | Number of Employees by Contract Type, Gender, and Country |
| B9 Health and Safety | Number and rate of reportable workplace accidents, including fatalities |
| B10 Compensation, Agreements, and Training | Compliance with the minimum wage, gender pay gap (if already required by law), percentage of staff covered by a collective bargaining agreement, average hours of training |
| B11 Corruption | Convictions and Fines for Corruption |
The complete module adds nine blocks designed for banks, investors, and major clients: business model and strategy (C1), details on practices and responsible individuals (C2), emissions reduction targets (C3), climate risks (C4), additional information on personnel such as turnover rate (C5), human rights policy and grievance mechanism (C6), confirmed incidents (C7), revenue from specific activities such as tobacco or fossil fuels (C8), and gender diversity on the governing body (C9). Scope 3 remains voluntary sector-specific information, particularly relevant in the manufacturing, agri-food, construction, and packaging industries.
Three factors make the VSME standard a realistic option for an SME:
- No dual materiality requirement and no mandatory external verification. The delegated regulation does not require your information to be verified by an assurance body.
- Amounts in Swiss francs. The text refers to monetary units rather than euros, making it applicable outside the eurozone.
- Your trade secrets remain protected. You may omit information whose disclosure would seriously harm your commercial position, provided you specify each instance and review this decision with each report.
Fewer than 10 employees: an even simpler system
If your company has 10 or fewer employees, several data points in the basic module become optional: energy and greenhouse gas emissions (B3), water withdrawals (B6), circular economy and waste (B7). In the comprehensive module, C1, C3, C4, C5, and parts of C6 and C7 also become optional. Most importantly, no data points from the comprehensive module may be required of a micro-enterprise under the value chain threshold.
How the VSME Standard Protects Your Small Business: The Value Chain Ceiling
The mechanism boils down to one rule. A company subject to CSRD reporting may not require a company in its value chain with an average of 1,000 employees or fewer to provide information that goes beyond the essential data points listed in Annex II of Delegated Regulation (EU) 2026/1560. These companies are referred to as “protected companies.”
What a client subject to the CSRD might still ask of you
According tothe analysis by the Belgian Institute of Corporate Auditors, Annex II distinguishes between two cases:
| Your company | May be required under the CSRD | Cannot be required under the CSRD |
|---|---|---|
| More than 10 employees | Key data from the core module (B1 through B11) and four sections of the comprehensive module: C1, C5, C6, and C7 | Scope 3, climate targets (C3), climate risks (C4), C2, C8, C9, sector-specific information, and voluntary disclosures |
| 10 or fewer employees | Essential data from the core module, excluding items that have become optional (energy and GHG emissions, water, waste) | The entire module, including optional data |
In practical terms, if a client asks you for your complete Scope 3 carbon footprint to include in their CSRD report, you can provide them with your VSME report and indicate that this data falls outside the scope. There’s nothing stopping you from providing it if you have it and if the business relationship warrants it: the decision is yours.
The Limits of the Shield: What You Need to Know Before Saying No
A ceiling that complies with the VSME standard does provide protection, but not in all cases. Before rejecting a claim, check these five points. The ceiling will not protect you if:
- The request relates to a fiscal year that began before January 1, 2027, since Article 3 of the regulation, which addresses the cap, applies only to fiscal years beginning in 2027 or later;
- the request serves a purpose other than CSRD reporting. The cap applies only to the collection of information for sustainability reporting and does not cover requests related to other regulations, such as the EU Deforestation Regulation;
- The request falls under the European due diligence obligation (CSDDD). In this case, a different rule applies: large companies may request information from their partners with fewer than 5,000 employees only if they cannot obtain it otherwise, as summarized in the OFJ’s explanatory report;
- Your client is not subject to the CSRD, a situation that has become common since the Omnibus Directive: their request falls under commercial negotiation, not under the law;
- You choose to disclose more information, for example, to retain a strategic contract.
In Switzerland, no equivalent rules currently exist: current law does not include any provisions protecting SMEs.The preliminary draft of the federal law on sustainable business management, which was released for public comment on April 1, 2026, adopts the European approach for large Swiss companies: they should provide appropriate support to SMEs in their supply chains and should only request information from them if they cannot obtain it otherwise. The Federal Council must submit its message to Parliament by November 27, 2026.
Mini-Case Study: A Small Business in Vaud Faces Three Questionnaires (Illustrative Example)
The company described here is fictional: it is used to illustrate the reasoning, not to provide actual figures. It is a small-to-medium-sized industrial company in the canton of Vaud with fewer than 250 employees that manufactures precision parts. Within a few weeks, it receives three inquiries.
Request 1: A German industrial group subject to the CSRD. The questionnaire covers energy, workforce, and workplace accidents, as well as Scope 3 emissions and a climate transition plan.
Rationale: The client is subject to the CSRD, and the threshold applies starting in fiscal year 2027. Energy, workforce, and accidents fall under the basic module. Scope 3 and the transition plan fall outside the threshold.
Answer: The SME submits its VSME report (Option B) along with a brief introductory statement, such as: “Please find attached our report prepared in accordance with the voluntary VSME standard, covering both the basic and comprehensive modules.” Scope 3 emissions are not included in the information covered by the value chain cap (Annex II of Delegated Regulation (EU) 2026/1560): we are not reporting them at this stage.”
Request 2: A mid-sized French client that is no longer subject to CSRD requirements under the Omnibus Directive.
Rationale: The cap does not legally apply, since the client no longer prepares a CSRD report.
Response: The SME submits its VSME report in place of its in-house questionnaire. The client remains free to accept, but receives data structured according to a recognized European standard, which often facilitates agreement.
Request 3: their bank, when renewing a loan.
Rationale: This request has nothing to do with the CSRD. The comprehensive module was specifically designed to meet the needs of banks, investors, and major clients, and KPMG Switzerland emphasizes that a VSME-compliant report helps SMEs consistently meet banking requirements.
Answer: the same VSME report, with no additional work.
One set of data, three responses: this is where the VSME standard saves the most time.
Prepare Your VSME Report in 6 Steps
- Compile a list of the requests received. For each client, note the country, whether they are subject to the CSRD, the applicable framework (CSRD, due diligence, commercial request, bank), and the deadline. This table will show you where the threshold applies and where it does not.
- Choose your option. Option A of the VSME standard (basic module) is often sufficient to get started. Option B becomes useful as soon as banks or large clients begin making regular requests.
- Collect data from existing records. Your electricity, gas, and fuel bills show energy consumption in MWh and provide the basis for calculating Scopes 1 and 2. Your employee registry includes headcount by contract type, gender, and country. Accident reports submitted to your accident insurer provide data for B9, and waste collection invoices provide data for B7.
- Draft the report. Indicate the option selected and the declaration of compliance, express amounts in francs, and note any information omitted for confidentiality reasons.
- Decide whether to have an external audit conducted. It is not mandatory. It can enhance your credibility if a bank or a major client requests it.
- Reuse the report wherever possible. Share it with your clients and your bank, and use it as a basis for your assessments. EcoVadis has recognized VSME as a reporting standard in its questionnaire since October 2025, and the Swiss tool esg2go offers reporting in the VSME format. If you’re preparing for an EcoVadis assessment at the same time, the article “I Need to Fill Out an EcoVadis Questionnaire: How Should I Get Organized?” will help you structure your supporting documentation.
Two tools should soon make this process easier: EFRAG has announced a digital model for November, and SECO is exploring the possibility of making the standard accessible to Swiss SMEs through an existing digital tool in the EU or one of its member states.
FAQ on the VSME Standard for Swiss SMEs
No. No Swiss law mandates the VSME standard, and it remains voluntary in the EU as well. The preliminary draft of the federal law on sustainable business management is aimed at large companies, not SMEs. In reality, it is your clients and your bank that make this issue unavoidable.
The cap sets a maximum, not a mandatory format. Nothing in European law requires you to prepare a VSME report, but a client subject to the CSRD may request the information covered by Annex II, in the format of their choice or as negotiated between you and them. In practice, the VSME report remains the simplest solution, since it covers exactly what that client is entitled to request.
No, verification by an insurance agency is not required by the delegated regulation. It remains an option if a partner requests it or if you want to build confidence in your figures.
No, these tools serve different purposes. The VSME standard defines what data to publish and in what format. EcoVadis assigns a score evaluated by analysts, which is often required by the procurement departments of large corporations. esg2go, developed in Switzerland, combines scoring and reporting. A well-structured VSME report feeds into both of the others.
Moving from a requirement to a ready-to-use ESG portfolio
Every questionnaire received without prior preparation costs time. With an up-to-date VSME report, you can respond faster, know what you can decline, and speak the same language as your European clients. If you find yourself thinking , “I have to do this—just make it simple, ” start with the data you already have: energy, workforce, and accidents. These already cover three indicators from the basic module (B3, B8, and B9).
To speed up the process, Coptain’s experts will work with you to conduct a CSR audit and develop a CSR action plan that compiles this data, identifies gaps, and prepares a reusable report for your clients, your bank, and your evaluations. To get a sense of where you stand, takethe online CSR self-diagnosis.
