CSRD reporting requirements

A VSME guide for North American suppliers

If a European customer is sending sustainability questionnaires, CSRD reporting requirements are the reason, and your data is part of their compliance obligation. VSME, the Voluntary Sustainability Reporting Standard for non-listed SMEs, is the standardized format designed to make that exchange consistent and repeatable. With the right preparation, most North American companies can respond without building a full compliance function from scratch.

Table of contents

THE COMPLIANCE CHAIN

Why are European customers sending sustainability questionnaires?

Your European customers are asking because CSRD, the Corporate Sustainability Reporting Directive, requires them to report on their value chain, and you’re part of it. After the EU’s Omnibus I Directive took effect in March 2026, CSRD applies to companies with more than 1,000 employees and more than €450 million in turnover. That population still includes most large European buyers. When they file their reports, their auditors expect traceable, consistent data from suppliers. That means they need numbers from you, and historically, every company asked for them differently. A procurement team sent a spreadsheet. A bank sent a portal questionnaire. A customer success contact sent a PDF. None of it matched. VSME was designed to fix that fragmentation problem.

ONE STANDARD, MANY REQUESTS

What is VSME, and how does it work?

VSME, the Voluntary Sustainability Reporting Standard for non-listed SMEs, gives smaller companies in European supply chains a single, consistent format to use when responding to data requests. It was published by EFRAG in December 2024. In July 2025, the European Commission formally recommended that large companies base their requests on VSME, which is why you’re starting to see it referenced in customer questionnaires.

VSME has two layers. The Basic Module covers 11 topics: company information, energy use and greenhouse gas emissions, pollution, biodiversity, water, waste, workforce, health and safety, pay and training, and corruption-related convictions. The Comprehensive Module adds nine more: business strategy, climate targets, climate risks, detailed workforce data, human rights policies, human rights incidents, sector-specific revenue, and governance diversity. For most North American suppliers responding to corporate or financial customers, the Comprehensive Module is the relevant target. The completed disclosure runs roughly 15 to 25 pages.

Who it applies to

Who should be preparing a VSME response?

You should prepare a VSME response if any of the following apply:

  • You export to Europe, or you sell to a North American company that does

  • You’re a European customer has sent a sustainability questionnaire, or you expect one in the next 12 months

  • Your bank, insurer, or investor has European exposure and is asking about climate risk

  • You want to position your business as a preferred supplier in procurement processes that score on sustainability reporting data

If none of these apply yet, there’s no immediate urgency. But the pattern is spreading. Canadian companies selling to EU clients are seeing the same requests. U.S. companies subject to California’s SB 253 emissions reporting requirements are beginning to push similar questions down their own supply chains. Preparing a VSME response once means you can answer whichever version comes first — and reuse most of the data year over year.

INSIDE A VSME SUBMISSION

What does completing a VSME submission actually look like?

For a first-time submission, budget 40 to 80 hours of internal work, depending on how much of your data is already organized digitally. The second year is significantly faster because most data carries forward. The work divides into four areas.

  • 1
    First, your carbon footprint: energy use, Scope 1 and 2 emissions, and Scope 3 where material. This is the largest, most technical piece, and it needs to be auditable.
  • 2
    Second, other environmental data: water, waste, and where relevant, biodiversity and pollution – data you may already collect for operational reasons.
  • 3
    Third, workforce and governance information: headcount, gender breakdown, turnover, pay, training, and health and safety metrics, plus governance diversity and revenue by sector from finance.
  • 4
    Fourth, narrative disclosures: short descriptions of your policies, practices, and climate targets — typically one to three paragraphs each.

Ownership most often falls to a finance or operations director, a sustainability lead if you have one, or an outside accountant who already supports your financial reporting.

YOUR DATA, READY TO GO

How does Greenplaces help with a VSME submission?

Greenplaces produces the audit-ready carbon footprint at the heart of any VSME submission. That includes energy use, Scope 1, 2, and 3 emissions, and the underlying activity data, emission factors, and evidence trail your auditor (or your customer’s auditor) will ask to see. We also capture a significant portion of the other environmental data VSME requires, including water and waste, along with the site-level information needed for biodiversity and water-stress assessments.

For workforce, governance, and narrative disclosures, our sustainability reporting software helps you organize and store that information so it sits alongside your footprint when a request arrives. Many of our customers pair Greenplaces with an accounting firm or outside advisor for final review, and we integrate cleanly into that workflow. The practical result: when a European customer sends a questionnaire, you have most of the answers already, presented in a format the customer and their auditor will recognize.

KNOW YOUR SCOPE

What does VSME not replace?

VSME is a powerful foundation, but it doesn’t substitute for other specific obligations. If your company has more than $1 billion in global revenue and does business in California, you’re separately subject to SB 253 emissions reporting requirements, with Scope 1 and 2 due August 10, 2026. If you export steel, aluminum, cement, fertilizer, hydrogen, or electricity to Europe, the EU’s Carbon Border Adjustment Mechanism applies and has its own installation-level data requirements that run parallel to VSME. Specialized industry questionnaires, including CDP Supply Chain and EcoVadis, are not replaced by VSME either, though most of your VSME data can be mapped directly into them.

Understanding where VSME fits — and where it doesn’t — helps you prioritize. Most North American companies responding to European customer requests can start with VSME and assess the others from there.

Make it real

What to do next

If you’ve just received a sustainability questionnaire from a European customer, start with your carbon footprint. It’s the largest, most technical piece of a VSME submission, and once it’s in place, the rest moves significantly faster. If you already have a documented footprint, you’re further along than most companies at this stage. Your next step is to confirm what environmental and HR data you already collect — much of it likely lives in your operations or HR systems — and identify where the gaps are. From there, an emissions reporting software platform like Greenplaces can handle a meaningful portion of the data collection automatically, reducing the burden on your team. If you want to understand exactly what a VSME response would look like for your business, we’re happy to walk through your specific situation in a 30-minute conversation.

  • Start with your carbon footprint.
  • Run a gap analysis. Confirm what environmental and HR data you already collect, and where the gaps are.
  • Collect data. Greenplaces’s platform can automate this for you.
Report with confidence

Contact Greenplaces today. We’ll walk through what the work actually looks like on a VSME submission — and where we can automate the process.

Frequently asked questions

No. VSME is voluntary for non-listed SMEs. However, if your European customers are required to report under CSRD, they may request that you respond in VSME format as part of their value chain disclosure. Completing a VSME response allows you to meet those requests consistently, without creating a new process for every customer.

CSRD is the EU reporting directive that applies to large companies — after the Omnibus I Directive, those with more than 1,000 employees and €450 million in turnover. VSME is the voluntary standard designed to help smaller companies in European supply chains respond to data requests from CSRD-scoped companies. Your North American business likely doesn’t fall under CSRD directly, but your European customers do, and they need your data to comply with their own CSRD reporting requirements.

For a first-time submission, most companies should budget 40 to 80 hours of internal time. That range assumes you’ll need to gather and organize data that isn’t yet in a central system. The second year is significantly faster because most data carries forward and your reporting infrastructure is already in place.

The largest piece is your carbon footprint: energy use, Scope 1 and 2 emissions, and Scope 3 where material. Beyond that, you’ll need environmental data (water, waste), HR data (headcount, gender, turnover, pay, training, health and safety), and short narrative descriptions of your policies and governance practices. A sustainability reporting platform can automate a meaningful portion of the data collection.

Yes. The VSME Comprehensive Module includes Scope 3 emissions where material. For most North American suppliers, that means accounting for indirect emissions across your value chain — upstream purchases and downstream distribution at minimum. If you’re already using carbon accounting software to track your footprint, much of this data may already be available.

In most cases, yes. Preparing a VSME submission creates a data foundation that maps to CDP Supply Chain questionnaires and EcoVadis assessments with relatively little additional work. The frameworks differ in structure, but the underlying data — emissions, energy, water, waste, workforce metrics — overlaps substantially across all three.

Yes. VSME was designed with smaller companies in mind. The Basic Module is manageable for most businesses with existing financial and operations records. The Comprehensive Module requires more work but is achievable with the right tools and, where needed, outside support from an accountant or sustainability reporting software platform.

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