VSME Basic Module: The 11 Disclosures B1 to B11 and the Data Behind Each

The standard is adopted under Article 29ca(1) of Directive 2013/34/EU, as inserted by Article 2(8) of Directive (EU) 2026/470 (Omnibus I), for undertakings not subject to Articles 19a and 29a. Which undertakings stay outside those articles is set out where the Corporate Sustainability Reporting Directive (CSRD) is explained.

This page covers each disclosure with its datapoints, the conditional datapoints, the changes against the 2025 Recommendation and the sources of the data.

The Basic Module at a Glance: Role, Option A and the Compliance Statement

The Basic Module is the target approach for micro-undertakings and the minimum requirement for every other undertaking that reports under the voluntary standard (Annex I paragraph 6(a)). The standard is intended for undertakings that, on their balance sheet dates, do not exceed an average of 1,000 employees during the preceding financial year (Annex I paragraph 2), including self-employed persons and listed micro undertakings. It is voluntary: Article 2(1) of Delegated Regulation (EU) 2026/1560 lets undertakings disclose sustainability information in accordance with Annex I, and paragraph 4 states that it does not impose legal reporting obligations unlike the ESRS.

An undertaking applies Option A (the Basic Module only) or Option B (the Basic Module and the Comprehensive Module) and states its compliance explicitly. "A module shall be complied with in its entirety" (paragraph 27(a)). The Basic Module is also the prerequisite for the Comprehensive Module (paragraph 7).

The standard creates no assurance obligation (recital 5). The report can be a separate section of the management report or a separate document (paragraph 20). Both options are summarised on the hub page for the voluntary standard's two modules.

The 11 Disclosures B1 to B11 and Their Datapoints

Annex I splits the Basic Module into two general disclosures, B1 and B2, and nine Basic Metrics, B3 to B11, each in its own paragraphs (paragraph 6(a)). Table 1 gives the paragraphs, the datapoints, the 10-employee marker and the cap coverage.

No official total number of datapoints exists.

B1 Basis for Preparation

B1 states which option the undertaking applies, with its statement of compliance, and gives the basic facts about the undertaking (paragraphs 27 and 28). It also states the individual or consolidated basis and the subsidiaries covered (paragraph 27(c)). It may omit information on the grounds in paragraph 22: seriously prejudicial commercial information in exceptional cases, trade secrets, classified information, and information protected under other Union or national law or for privacy or security reasons.

The general information in paragraph 27(e) comprises seven items.

• Legal form
• NACE code(s)
• Balance sheet total
• Turnover
• Employees, as headcount or full-time equivalents
• Country of primary operations and significant assets
• Geolocation of sites owned, leased or managed

Paragraph 28 adds a short description of sustainability-related certifications or labels.

B2 Practices, Policies and Future Initiatives

B2 asks whether the undertaking has practices, policies, future initiatives and targets for transitioning towards a more sustainable economy (paragraphs 29 to 31). The full description of those practices belongs to C2 in the Comprehensive Module.

B3 Energy and Greenhouse Gas Emissions

B3 asks for total energy consumption in MWh and for estimated absolute gross greenhouse gas emissions in tonnes of CO2 equivalent, Scope 1 and location-based Scope 2 (paragraphs 32 and 33). Paragraph 32 adds the renewable and non-renewable breakdown for electricity and fuels "if obtainable"; paragraph 33 takes the GHG Protocol Corporate Accounting and Reporting Standard (2004) as its reference. Both paragraphs are voluntary for undertakings with 10 employees or less.

B3 has no GHG intensity datapoint. The scope definitions are on the page for Scope 1 and Scope 2 emissions under ESRS E1.

B4 to B7 Pollution, Biodiversity, Water, Resource Use and Waste

The four further environmental disclosures each ask for a short set of figures, most of them only when a stated condition applies.

• B4: pollutants to air, water and soil from the undertaking's own operations that it already reports to authorities under EU or national law or under an environmental management system, with a reference to a public document allowed (paragraph 34).
• B5: sites in or near a biodiversity-sensitive area, and the name of that area (paragraph 35).
• B6: total water withdrawal, and water consumption where processes are significantly water-consuming, shown separately for sites in areas with water stress (paragraphs 36 and 37).
• B7: whether and how circular economy principles are applied, total waste split into hazardous and non-hazardous, the proportion diverted to recycling or preparation for reuse, and the annual mass-flow of relevant materials where material flows are significant (paragraphs 38 and 39).

B8 to B10 Workforce Metrics

Three disclosures cover the workforce: its composition, accidents, and pay, collective bargaining and training.

• B8: employees by type of contract, by gender and, where there is more than one country, by country of employment contract (paragraph 40).
• B9: number and rate of recordable work-related accidents and, subject to legal restrictions, fatalities from recordable work-related accidents and ill health (paragraph 41).
• B10: compliance with the minimum wage (42(a)); the female and male pay gap, only where EU law or other national regulations already require its disclosure (42(b)); the percentage of employees covered by collective bargaining agreements (42(c)); and the average annual training hours per employee (42(d)).

B11 Convictions and Fines for Corruption and Bribery

B11 asks for the number of convictions and the total amount of fines for violations of anti-corruption and anti-bribery laws (paragraph 43).

"If Applicable" Datapoints and the 10-Employee Voluntary Layer

Not every Basic Module datapoint applies to every undertaking: some apply only in the circumstances the standard specifies, and an omitted one "is assumed to not be applicable" (Annex I paragraph 15). The conditions sit in B4, B5, B6, B7, B8 and B10(b), as the sections above show. The standard distinguishes four kinds of datapoint: essential, "if applicable", voluntary and sector-specific (recital 3, paragraph 8).

Some essential datapoints are marked "[Voluntary for undertakings with 10 employees or less]" (recital 3, paragraph 8). In the Basic Module the marker sits in B3 (paragraphs 32 and 33), B6 (paragraphs 36 and 37) and B7 (paragraphs 38 and 39). The marked datapoints stay in the standard; an undertaking with 10 employees or less may leave them out.

What Changed in the Basic Module since the 2025 Recommendation

Delegated Regulation (EU) 2026/1560 is based on Recommendation (EU) 2025/1710 of 30 July 2025 (CELEX 32025H1710), as Article 29ca(2) of Directive 2013/34/EU requires, and it changed several Basic Module datapoints, the most visible being the deletion of GHG intensity from B3. The regulation was published in the Official Journal on 21 September 2026 and has been in force since 24 September 2026; the Recommendation no longer produces legal effects since 24 September 2026 (recital 5). The intended users changed too, as Table 2 shows. The full list of changes is on the page for what Delegated Regulation (EU) 2026/1560 changed for the voluntary standard.

The Recommendation's practical guidance in Annex II (paragraphs 1 to 144 for the Basic Module) is replaced by EFRAG's practical guidance, which undertakings may use under Article 2(2).

Where the Basic Module Data Comes From

Most Basic Module figures come from records an undertaking already holds for other purposes, and the standard names some of those sources itself. B4 draws on reports to authorities or an environmental management system (paragraph 34), B3 follows the GHG Protocol Corporate Standard of 2004 (paragraph 33) and EMAS reporters can combine reports (paragraph 19). From the second year of reporting, comparatives for the previous year are added, except for metrics disclosed for the first time (paragraph 14).

EFRAG's guidance on the voluntary standard is non-mandatory and does not extend or add to the provisions of the regulation. The EFRAG Digital Template, version 1.3.0 of 11 June 2026, is still built on the Recommendation, and no template based on the voluntary standard has been released as of 29 October 2026. The fields of the EFRAG digital template for Basic Module data are covered on their own page.

Preparing a Basic Module Report with Software or a Preparer

A Basic Module report can be prepared in-house, with VSME reporting software or with an external preparer, and the choice does not change what the standard requires. Each route works from the same inputs: the option chosen, the number of employees, the sites and the energy and waste records behind B1, B3 and B7.

To compare tools first, see what VSME reporting software does; in-scope customers' reporting steps are in our CSRD compliance plan.

Basic Module Requests from Customers and Banks

Customers that report under the CSRD and banks often send Basic Module questions, and what a reporting customer may ask of an undertaking with up to 1,000 employees is limited to the datapoints listed in Annex II. Annex II lists 9 rows for undertakings with 10 employees or less and 23 rows for undertakings with more than 10 (rows, not datapoints), as the cap column of Table 1 shows. Article 4 of Delegated Regulation (EU) 2026/1560 applies the cap list from financial years beginning on or after 1 January 2027. The rules on the value-chain cap on what customers may ask suppliers are on their own page.

Financial institutions are "still encouraged" to limit their requests to undertakings with 1,000 employees or less, for purposes beyond sustainability reporting under Directive 2013/34/EU, to the information in Annex I (recital 5). The text is an encouragement, not an obligation.

Basic Module Questions

Five questions recur about the Basic Module.

Does a micro-undertaking have to report every Basic Module datapoint?

No: datapoints marked voluntary for undertakings with 10 employees or less may be left out, and "if applicable" datapoints apply only where their condition is met, while the rest of the module is complied with in its entirety under Option A. The position of micro-undertakings and SMEs under the CSRD is set out separately.

Is GHG intensity still part of B3?

No: Annex I of Delegated Regulation (EU) 2026/1560 has no GHG intensity datapoint; it was paragraph 31 of Recommendation (EU) 2025/1710 (gross emissions divided by turnover).

Must a Basic Module report be assured?

No: undertakings applying the voluntary standard are not obliged to seek assurance (recital 5 of Delegated Regulation (EU) 2026/1560).

Must Basic Module reporters assess materiality?

No: the voluntary standard requires no double materiality assessment and uses the "if applicable" principle of Annex I paragraph 15 instead.

Can an undertaking add Comprehensive Module disclosures to Option A?

Yes: the EFRAG Secretariat stated at its event of 9 October 2026 that an undertaking may state Option A and add selected Comprehensive Module disclosures. The Comprehensive Module disclosures C1 to C9 are explained on the sibling page.