The VSME standard: Understanding the Comprehensive Module

The Omnibus proposal has reshaped sustainability reporting obligations, lifting the Corporate Sustainability Reporting Directive (CSRD) requirements for over 40,000 businesses. But while compliance may no longer be mandatory for most companies, the demand for ESG transparency hasn’t disappeared.

Banks, investors, and corporate partners still expect sustainability data — and companies that continue structured ESG reporting will maintain a competitive edge in financing, partnerships, and long-term resilience.

For businesses that want to go beyond the basics, the VSME Comprehensive Module offers a scalable, investor-ready approach to ESG reporting. It builds on the Basic Module with deeper insights into business strategy, climate action, social impact, and governance practices—all while keeping reporting proportional, practical, and adaptable to different industries.

This guide walks you through what’s inside the Comprehensive Module, why it matters, and how to get started.

VSME: A two-tier ESG reporting framework

The VSME Standard is designed for businesses that want to measure, track, and communicate sustainability performance without the complexity of CSRD compliance. It offers two levels of reporting:

Basic Module: The foundation

Covers essential ESG disclosures such as energy use, emissions, workforce composition, and anti-corruption compliance. Ideal for companies looking for a streamlined approach to ESG reporting.

Comprehensive Module: The Full ESG report

Expands on the Basic Module with deeper disclosures on:

✔️ Business strategy and risk management
✔️ GHG reduction targets and climate transition plans
✔️ Detailed social and human rights policies
✔️ Sector-specific ESG considerations

Key rule: Companies must include the Basic Module when reporting under the Comprehensive Module, ensuring a structured, step-by-step approach to ESG transparency.

What’s inside the Comprehensive Module?

The Comprehensive Module contains around 100 ESG data points (compared to 1,100 in CSRD), making it a proportional but meaningful alternative to full CSRD compliance.

It builds on the Basic Module across four key ESG categories:

1. Strategy & business model

• Key products and services – How they impact sustainability
• Significant markets – B2B, B2C, wholesale, and country-specific operations
• Operational business relationships – Supply chain, key suppliers, and customer dependencies
• If applicable: Sustainability-linked elements in business strategy

2. Environmental strategy & climate transition

• GHG reduction targets – Scope 1 & Scope 2 reduction goals
• Optional but recommended for businesses with complex supply chains: Scope 3 emissions reporting climate adaptation strategies – Risk assessments for climate-related events
• Time horizons for climate risks – Short, medium, and long-term analysis

For companies with high environmental impact:

• Expanded pollution disclosures – Air, water, and soil emissions
• Water risk assessments – More granular tracking of water use and wastewater discharge

3. Social & human rights disclosures

• Diversity & inclusion
  
  • For companies with 50+ employees)Female-to-male ratio at the management level: Breakdown of temporary vs. permanent workers
• Human rights policies & due diligence
  
  • Code of conduct addressing:
    
    • Child labor
    • Forced labor
    • Human trafficking
    • Discrimination
    • Workplace safety
  • Incident reporting – Confirmed cases of human rights violations within the company or supply chain
  • Whistleblower protections – Complaint-handling mechanisms for human rights concerns

4. Governance & financial transparency

• If applicable: Sector-specific ESG reporting
  
  • Revenue breakdown for companies in controversial industries (fossil fuels, weapons, tobacco, etc.)
  • If relevant: Exclusion from EU reference benchmarks
• Corporate governance
  
  • Gender diversity at board and executive levels
  • Disclosure of anti-corruption and bribery incidents

{{custom-cta}}

How to implement the Comprehensive Module

Step 1: Review your ESG data readiness

Start by assessing:

✔️ What ESG data is already available (energy bills, payroll records, supplier data)
✔️ Where there are gaps (climate risk assessments, human rights policies, governance disclosures)
✔️ What industry-specific disclosures apply to your business

Tip: If your company has already conducted a double materiality assessment under CSRD or tracked ESG data in other frameworks, you’re already well-prepared for VSME reporting.

Step 2: Collect the Necessary Data

• Energy & emissions tracking – Ensure Scope 1 & Scope 2 data is complete; consider estimating Scope 3 emissions if supply chain impact is significant.
• Diversity & social data – HR teams should compile gender, contract type, and training records.
• Governance & compliance records – Review corruption risk assessments, bribery disclosures, and board diversity stats.
• Risk mapping & sustainability strategy – Identify where climate risks, social responsibility policies, and ethical sourcing impact your business model.

Step 3: Report & Share Your ESG Data

Decide where your Comprehensive VSME report will be used:

• Internal reporting – For management and board-level decision-making
• Investor & bank disclosures – To strengthen financing and lending opportunities
• Supplier & client ESG requests – To remain competitive in sustainability-driven supply chains
• Optional: Public sustainability reporting – For brand credibility and transparency

Why choose the Comprehensive Module?

With CSRD requirements easing under Omnibus, many businesses are reconsidering how much ESG data to disclose. But for those that want to maintain credibility with stakeholders, structured reporting remains essential.

The Comprehensive Module allows businesses to:

✔️ Meet investor and bank expectations without the administrative burden of CSRD
✔️ Strengthen supply chain credibility by demonstrating sustainability leadership
✔️ Future-proof ESG strategy by aligning with evolving global sustainability trends
✔️ Showcase responsible governance through structured risk management and compliance reporting

Bottom Line? The Comprehensive Module provides a scaled-down but strategic ESG framework — delivering value without excessive compliance costs.

What’s next?

Investors, banks, and large business partners still expect sustainability data, and having a structured ESG report helps you build trust, secure financing, and future-proof your organization. The VSME standard provides a manageable, actionable framework that allows businesses to report on ESG performance without excessive complexity.

To guide this process, Coolset has launched a dedicated and modular VSME module: starting with the Basic framework and extending into Comprehensive. It’s designed to streamline reporting while setting you up with an end-to-end sustainability management platform for both current and future ESG needs.

Want to learn more? Find a time with our team.

‍