What happened
On 9 October 2026, EFRAG held an outreach event in Brussels on the new Delegated Act on the Voluntary Standard (VS), which replaces the VSME Recommendation. The European Commission (DG FISMA) and EFRAG explained what has changed, and national platforms, banks and business organisations shared how the standard is being used in practice.
Key points
Value chain cap: the Delegated Act limits how much sustainability information large companies and banks can request from SMEs and other companies outside the CSRD scope.
No double materiality assessment: the VS does not require one. It is replaced by the “if applicable” principle.
No assurance requirement for voluntary reporting under the VS.
Modules: you report your chosen module in full. Only datapoints marked “if applicable” may be left out, and only when their conditions are not met.
Step by step: you can report the Basic Module and add selected disclosures from the Comprehensive Module, as a way to move towards the full Comprehensive Module over time.
Guidance: the updated VS Guidance (former Annex II) is available on the EFRAG Knowledge Hub and will be translated into all EU languages by December 2026.
Digital Template: an updated version comes in November 2026, with Word format for narrative disclosures, comparison with the previous period and a merge tool.
Uptake: France’s Portail RSE has about 500 available reports and 2,000 companies that have started one. Germany’s DNK has almost 5,700 registered users and around 4,000 reports in progress.
What it means for you
If customers or banks send you ESG questionnaires: the VS is becoming the common baseline. Banks in Belgium (KUBE ESG), Germany (DNK) and Italy (Banco BPM) see it as the basis for their ESG questions, although some extra datapoints will remain. One VS report can answer most of the basic questions.
If you request data from suppliers: the value chain cap means requests should build on the VS. Keep extra questions to what you actually need, for example sector-specific risks.
If you are starting now: choose the Basic or the Comprehensive Module and report it in full. If you plan to use EFRAG’s Digital Template, the updated version comes in November 2026.
Source
EFRAG Secretariat summary report “From VSME to the Voluntary Standard: A practical approach to sustainability reporting”, Brussels, 9 October 2026. The report has not been reviewed by the EFRAG SRB or SR TEG. Slides and video recordings are available on EFRAG’s event page.










