The European Financial Reporting Advisory Group (EFRAG) finalized the Voluntary Standard (VS), and I recently sat through a presentation on its final elements. While the presenters know that application needs to be considered, the final VS is public, it's free, and it sits on EFRAG's Knowledge Hub. If your customers report under CSRD, it's the current document that defines what they can ask of you.
Where to find it
The final VS lives on EFRAG's Knowledge Hub, and anyone can read it. Its formal name is a mouthful: the standard for voluntary use by undertakings protected by the value chain cap. It's Annex I of Commission Delegated Regulation (EU) 2026/1560, adopted July 3 and published in the Official Journal on September 22, alongside the revised ESRS.
EFRAG has also posted non-mandatory guidance next to the standard, with templates and definitions for each disclosure — the reference provides details such as how to count full-time equivalents, for example.
What's in it
The VS can be used by companies that are not in scope for CSRD reporting. It covers the same sustainability issues as the ESRS, scaled down, and it creates no legal reporting obligation of its own.
SMEs will not need to complete a double materiality assessment. SMEs can report based on what is applicable to their company.
The VS structure itself has two modules, a Basic Module that every company reporting to the VS completes and a Comprehensive Module (which adds to the Basic Module) for companies facing heavier stakeholder demands.
|
Module |
Disclosures |
Built for |
|---|---|---|
|
Basic |
B1–B2: basis for preparation; practices, policies, and future initiatives B3–B7: energy and GHG emissions, pollution, biodiversity, water, resource use, and waste B8–B10: workforce characteristics, health and safety, pay, collective bargaining, and training B11: corruption and bribery convictions and fines |
The Basic Module alone is usually sufficient for micro and smaller companies. |
|
Comprehensive |
C1–C2: business model and strategy; practices and policies C3–C4: GHG reduction targets and climate risks C5–C7: added workforce data, human rights policies, and incidents C8–C9: revenue from certain sectors; governance gender diversity |
The Comprehensive Module adds complexity including increased data and introduces targets. |
A few details are worth knowing before a customer request lands:
- Scope 3 isn't a required metric. B3 asks for Scope 1 and 2. Scope 3 is something a company can add when it's relevant to its sector, and the standard names manufacturing, agrifood, real estate construction, and packaging as likely cases. EFRAG's guidance suggests screening all 15 GHG Protocol categories with estimates to find the significant ones.
- Size plays a role inside the standard, too. Some data points are voluntary for companies with 10 or fewer employees, marked in square brackets in the text.
- Omissions are allowed, with disclosure. A company can leave out trade secrets, classified information, or seriously prejudicial information, as long as it says which datapoints it omitted.
What it caps
The VS does double duty. It's a reporting framework for smaller companies, and it's the ceiling on what CSRD reporters can request from companies in their value chain that fall below the CSRD thresholds.
The cap is narrower than the full VS. Annex II lists the specific data points it covers, and the list depends on your company’s size.
|
Company size |
Datapoints covered by the cap |
|---|---|
|
10 employees or fewer |
B1 company basics (module chosen, reporting basis, legal form, sector, size, sites) B8 employees by contract type and gender B9 recordable work accidents B10 minimum wage, collective bargaining coverage, and training hours |
|
More than 10 employees |
Everything above, plus: B3 energy use and estimated GHG emissions. B6 water withdrawal. B7 circular economy practices, total waste and recycling share C1 products, markets, and main business relationships C5 employee turnover C6 code of conduct or human rights policy and complaints mechanism C7 confirmed human rights incidents |
In plain terms: If your company is outside of CSRD reporting requirements and gets a request for data, Annex II is designed to be the line. Anything beyond it is meant to be optional.
The final standards have prompted questions
In practice, those outside of the CSRD reporting scope should find the VS as a reporting roadmap to satisfy sustainability reporting. However, there are some caveats to consider.
- Some SMEs expressed concern that the CSRD legislative and regulatory guardrails will be challenged by CSRD reporters, with some preparing for requests beyond the guardrails.
- Additional concerns have been raised for companies outside of the EU. It is unclear how they might be protected from an EU-based regulation.
As EFRAG continues to weigh the practical application of the VS,
Companies in and outside of the EU are still working to prepare for CSRD reporting or aligning with the VS or other voluntary reporting. If you are reading this and thinking of the uncertainty that your organization is facing, you are not alone. We recommend a few actions in the short-term:
- Read the standard. It's free on the Knowledge Hub, along with EFRAG's non-mandatory guidance and templates.
- Map what your customers already ask for against Annex II. That shows you which requests sit inside the VS and which go beyond it.
- Start with the Basic Module. It's the minimum the standard expects, and it's the prerequisite for the Comprehensive Module.
- Expect Scope 3 questions anyway. Scope 3 isn't required by the VS or listed in Annex II, but a CSRD reporter building its own Scope 3 inventory will likely still ask.
- If you're a company based outside of the EU, plan for requests beyond the VS. The current cap may not protect you, so decide now what you're prepared to share.
- Weigh in. EFRAG has welcomed input on its agenda to support ESRS and VS reporters and has requested public feedback through February 15, 2027. Share your input.
Sources: EFRAG Knowledge Hub, Voluntary Standard (Official Journal publication); ESG Today, Sept 22, 2026; EFRAG Knowledge Hub, Annex II; EFRAG, Voluntary Standard non-mandatory guidance; EFRAG presentation, Oct 12, 2026.
Suzanne McGovern brings more than 20 years of experience in sustainability strategy, corporate reputation, and ESG reporting to her role as Senior Director of Sustainability Strategy at thinkPARALLAX. She helps clients translate complex ESG requirements and stakeholder expectations into strategies and reports that hold up to scrutiny. Her client work spans a wide range of industries, including alcohol, data and analytics, technology, financial markets, and industrials — among them Heineken USA, Dun & Bradstreet, NCR, ICE, and Mueller Water Products.
