The EU’s Omnibus proposal has raised the CSRD employee threshold from 250 to 1,000, removing many Wave 2 companies from mandatory CSRD scope. But these companies still face sustainability reporting demands — from customers, investors, banks, and supply chain partners who are themselves subject to CSRD.

The Voluntary SME Standard (VSME) provides a structured, proportionate pathway for companies no longer required to report under CSRD but still needing to respond to stakeholder requests for sustainability data. This guide explains how to transition from CSRD preparation to VSME reporting.

Why the transition matters

Companies that have been preparing for CSRD have invested in their double materiality assessment, data collection processes, and sustainability reporting capabilities. This investment is not wasted — the work done for CSRD provides a strong foundation for VSME reporting and meets the needs of most stakeholder requests.

The key difference: VSME is proportionate and voluntary. It covers a focused set of sustainability disclosures aligned with what large CSRD reporters need from their suppliers — without the full complexity of the ESRS framework. For more on how the Omnibus changed CSRD scope, see our guide on CSRD under Omnibus.

CSRD vs VSME: what’s different

Understanding the differences helps you reuse CSRD work efficiently:

• Scope: VSME covers a subset of sustainability topics compared to full ESRS. Environmental data (GHG emissions, energy), basic social data (workforce), and governance fundamentals are all included — sector-specific and highly granular ESRS requirements are not.
• Materiality: VSME does not require a formal double materiality assessment, though the work done for CSRD provides useful context for prioritizing VSME disclosures.
• Assurance: VSME is voluntary and does not require third-party assurance, though companies may choose to have their disclosures reviewed.
• Format: VSME uses a simpler reporting format than ESRS, focused on practical metrics that supply chain customers and lenders can use.

How to reuse CSRD work for VSME

Most of the foundational work done for CSRD can be reused for VSME:

• GHG emissions data: Scope 1, 2, and 3 emissions measured for CSRD align directly with VSME environmental disclosures
• Workforce data: HR metrics collected for ESRS S1 carry over to VSME social disclosures
• Governance documentation: Policies and codes of conduct developed for ESRS G1 can be referenced in VSME governance disclosures
• Materiality insights: Even without a formal VSME DMA, the insights from your CSRD DMA help prioritize which VSME topics are most relevant to your stakeholders

What VSME adds that CSRD didn’t require

VSME has some specific disclosure formats that differ from ESRS. The VSME Basic Module and Narrative Policy Module have their own structure. You may need to reformat or supplement existing CSRD data to fit the VSME template.

For a detailed breakdown of what the VSME standard requires, see our guide to understanding the VSME Basic Module.

Practical steps for the transition

1. Confirm whether your company is out of CSRD scope under the Omnibus thresholds
2. Identify which customers, investors, or lenders are requesting sustainability data and what format they prefer
3. Map your existing CSRD data to the VSME reporting template
4. Identify any VSME disclosures that require new data collection
5. Publish your VSME report or share it with stakeholders on request

How Coolset supports the CSRD-to-VSME transition

Coolset’s platform supports both CSRD and VSME reporting. For companies transitioning from CSRD to VSME, the platform helps you understand how your existing data maps to VSME requirements. The VSME module provides a structured reporting workflow aligned with the current EU regulatory framework. Book a demo to see how it works.