Compare Your Footprint — Carbon Intelligence Platform

The European Commission is expected to publish the VSME delegated act in June 2026. When it lands, it will formalise exactly what sustainability data EU companies can request from their smaller suppliers — including UK SMEs exporting into European supply chains. If you supply goods or services to an EU customer, this standard will shape your next carbon data request.

Why VSME matters to your business

Since the EU Omnibus I Directive came into force on 18 March 2026, companies with fewer than 1,000 employees have gained a legal right to refuse data requests that go beyond the Voluntary SME Standard. That sounds protective — and it is — but it works both ways. EU procurement teams now have a clearly defined template for what they can ask for. And they will use it.

The practical effect: your EU customer’s sustainability questionnaire is about to become standardised. Instead of bespoke, inconsistent requests that vary by customer, you’ll face a common data format. That’s good news if you’re prepared, and a problem if you’re not.

What data VSME covers — and what it doesn’t

The VSME standard is deliberately narrower than full CSRD reporting. Based on the EFRAG draft, it covers three modules:

Basic module (all SMEs): General business information, governance practices, and high-level environmental and social policies. This is mostly qualitative — descriptions of what you do, not detailed metrics.

Business Partners module (supply chain focus): This is the module your EU customer cares about. It covers energy consumption, Scope 1 and Scope 2 GHG emissions, basic workforce metrics, and material environmental impacts. The data fields are specific: total energy in MWh, emissions in tonnes CO₂e by scope, and a description of your emissions reduction targets if any.

Financial Institutions module: Relevant only if your business is seeking green financing. Most SMEs can ignore this.

What VSME explicitly excludes: full Scope 3 reporting, lifecycle assessments, biodiversity impact metrics, and detailed climate scenario analysis. If your EU customer asks for any of these, the Omnibus I provision gives you grounds to push back.

5 actions to take before your EU customer’s next data request

1. Identify which of your customers are EU-reporting companies

Check whether any of your key customers are listed companies or large undertakings subject to CSRD. These are the companies whose procurement teams will standardise around VSME data fields. If you don’t know, ask your account manager or check the customer’s most recent annual report for CSRD references.

2. Collect your energy consumption data in MWh

VSME requires energy consumption in megawatt-hours. Most UK SMEs track energy in kWh on their utility bills — the conversion is straightforward (divide by 1,000). Collect 12 months of electricity and gas invoices. If you lease your premises and utilities are included in your rent, contact your landlord for the breakdown.

3. Calculate your Scope 1 and Scope 2 emissions

You need total emissions in tonnes CO₂e, split by Scope 1 (direct emissions from fuel you burn — gas boilers, company vehicles) and Scope 2 (indirect emissions from purchased electricity). The DESNZ conversion factors published annually by the UK government give you the multipliers.

4. Document your emissions reduction targets (if any)

VSME asks whether you have a target, what the baseline year is, and what the target year is. If you don’t have a formal target yet, that’s fine — state that clearly rather than fabricating one. A credible “we measured this year and are setting a target for next year” is better than an unsubstantiated net-zero claim.

5. Prepare a one-page summary in VSME format

When the delegated act publishes, CYF will map its reporting output to the final VSME data fields. In the meantime, prepare a summary covering: your reporting period, total energy in MWh, Scope 1 and 2 emissions in tonnes CO₂e, a brief description of your reduction approach, and key workforce metrics (headcount, health & safety incidents). This is the core of what VSME asks for.

Common misconceptions about VSME

“VSME means I have to report publicly.” No. VSME is a framework for responding to supply chain data requests. You’re not publishing an annual sustainability report — you’re answering your customer’s questionnaire in a standardised format.

“It only affects EU companies.” It affects any company in an EU company’s supply chain. If you’re a UK manufacturer supplying a German automotive company, VSME is the template they’ll use to ask for your data.

“I need a consultant to do this.” For Scope 1 and 2 data based on energy bills, most SMEs can self-serve with the right tool. According to Sage/ICC research, only 9% of SMEs have formal sustainability measurement processes — but the VSME data requirements are narrow enough that software handles the heavy lifting.

How CYF helps

CYF is built around UK frameworks — DESNZ conversion factors, SECR reporting requirements, and the data fields that UK SRS and VSME share. When the VSME delegated act publishes, CYF will map its output to the final standard so your export report matches what your EU customer expects. CYF’s benchmark dataset also means you can see how your emissions compare to other UK businesses in your sector — useful context when your customer asks whether your figures look “normal.”

Methodology guidance from Alice Roberts, Head of Methodology at Compare Your Footprint.

Start measuring before your customer’s next data request — try CYF free or read our SECR guide for SMEs.