Regulatory Alignment

Standards & Regulatory Alignment

How VSME OS reports satisfy the requirements of CSRD, GHG Protocol, ISO 14064-1:2018, and Commission Recommendation (EU) 2025/1710 (EU VSME) — and what remains the buyer's responsibility.

CSRD ESRS E1

Aligned

Scope 1, 2 (location & market), Scope 3 Cat. 6+7, intensity metric

GHG Protocol

Aligned

Activity-based method, operational control boundary, Scope 2 dual reporting

ISO 14064-1:2018

Aligned

Quantification, boundary statement, uncertainty disclosure, attestation

EU (2025/1710)

Aligned

SME-appropriate data points, proportionality principle, limited assurance

SBTi SME Pathway

Compatible

Scope 1+2 data directly usable for SBTi target-setting baseline

CDP Supply Chain

Compatible

Scope totals and intensity metric match CDP S3.1 supplier fields

EU Taxonomy

Partial

Provides GHG data for Do No Significant Harm climate assessment; full taxonomy requires additional disclosures

Ecovadis / Sedex

Compatible

Carbon footprint data can be imported into Ecovadis environmental scorecards

1. EU Corporate Sustainability Reporting Directive (CSRD)

The EU Omnibus Directive (published 26 February 2026, in force 18 March 2026) significantly revised the CSRD. Companies with more than 1,000 employees and over €450 million net turnover are now required to disclose Scope 1, 2, and Scope 3 emissions, with first reports due for financial year 2027 (published in 2028). The Omnibus explicitly names the VSME standard (Commission Recommendation EU 2025/1710) as the voluntary standard that value chain suppliers use to respond to buyer data requests — making VSME OS the direct implementation of that standard. Critically, in-scope companies are prohibited from requesting data from value chain partners that exceeds what the VSME voluntary standard covers. VSME OS generates exactly that data.

What CSRD ESRS E1 Requires from Suppliers

Under ESRS E1, large companies must disclose:

E1-6 — Gross Scope 1, 2, 3 GHG emissions (in tCO₂e)

Page 1 totals panel — all three scopes in tCO₂e

E1-6 — Scope 2 location-based AND market-based

Both methods reported. Grid electricity = location-based. Green electricity = market-based.

E1-6 — GHG intensity of net revenues

Two intensity metrics: kgCO₂e / M revenue currency (ESRS E1-6 compliant) and kgCO₂e / actual EUR (4 decimal places). Both shown on Page 1.

E1-6 — Emission factor sources disclosed

Primary database named per country. Scope 3 RF multiplier disclosed. Factor versions noted in footer.

E1-6 — Boundary statement and exclusions

Page 4 Section 5 lists every assessed but zero-activity source, grouped by scope (Scope 1 / 2 / 3)

E1-6 — Upstream Scope 3 Cat. 1 (purchased goods)

Not yet covered — Phase 3 roadmap

E1-5 — Transition plan and targets

Outside scope of VSME OS (measurement tool, not target-setting tool)

The CSRD Scope 3 Data Chain

How data flows from SME supplier to CSRD filing:

1

SME supplier enters emissions data in VSME OS

Scope 1, 2, 3 activity data

2

VSME OS generates PDF report (GHG Protocol compliant)

4-page: Summary · Breakdown · Declaration · Methodology

3

Supplier shares PDF with buying company

Via email, buyer portal, or procurement platform

4

Buyer ingests Scope 3 tCO₂e from Page 1

Into their Scope 3 Cat. 1 or Cat. 11 inventory

5

Buyer discloses aggregated Scope 3 in CSRD filing

Under ESRS E1-6, with supplier data as evidence base

2. GHG Protocol Corporate Accounting and Reporting Standard

The GHG Protocol Corporate Standard (WRI / WBCSD, 2004, updated 2015 for Scope 2) is the most widely used international framework for corporate GHG accounting and reporting. It defines Scopes 1, 2, and 3, the activity-based calculation methodology, and the requirements for boundary setting and disclosure.

Relevance

All material emission sources for a typical SME are included. Sources not yet covered are explicitly disclosed as boundary exclusions.

Completeness

All Scope 1, 2, and selected Scope 3 sources within the declared boundary are covered. Boundary is defined using the operational control approach.

Consistency

The same methodology, factors, and boundary apply across reporting years, enabling year-on-year comparison.

Transparency

Factor sources, update dates, assumptions (e.g. RF×1.9 for flights), and boundary exclusions are all disclosed on-report.

Accuracy

Country-specific emission factors from national authoritative databases. Self-attested (limited assurance) — disclosure is on-report.

Scope 2 Dual Reporting (GHG Protocol Scope 2 Guidance, 2015)

The 2015 update to the GHG Protocol introduced the requirement to report Scope 2 emissions using both the location-based and market-based methods. VSME OS implements both by default:

  • Location-based: Grid electricity consumption × country grid factor. Reported on Page 1 and Page 2.
  • Market-based: Green electricity consumption × 0.000 kgCO₂e/kWh (with GoO/REC certificate). Reported as a separate line on Page 2 and noted in the compliance block.

3. ISO 14064-1:2018 — Quantification of GHG Emissions

ISO 14064-1:2018 specifies principles and requirements for the quantification and reporting of GHG emissions at the organisation level. It is the international standard underlying the GHG Protocol and is referenced by CSRD as an acceptable quantification methodology.

ISO 14064-1 RequirementVSME OS Implementation
Organisational boundary (Clause 5.2)Operational control approach. Declared in report boundary statement.
GHG sources and sinks (Clause 5.3)All relevant emission sources categorised by scope and type. Exclusions documented.
Activity data (Clause 6.2)Supplier-entered data with evidence documentation listed in Declaration.
Emission factors (Clause 6.3)Country-specific, annually updated, source-cited in every report.
GHG assertion (Clause 7)Page 1 totals panel. Scope-level breakdown on Page 2.
Uncertainty assessment (Clause 6.5)Disclosed as self-attested (limited assurance) in disclaimer.
GHG report contents (Clause 7.2)All required elements present across 4 pages: summary, activity detail, declaration, and methodology & audit trail.

4. Commission Recommendation (EU) 2025/1710 — EU VSME Standard

The European Commission published the Voluntary Sustainability Reporting Standard for SMEs (VSME) as Commission Recommendation (EU) 2025/1710, signed in Brussels on 30 July 2025. It is designed to allow SMEs to report sustainability data proportionately — without the full burden of ESRS that applies to large companies — while still producing data that is useful for their buyers' CSRD disclosures.

VSME OS is named after and built around this standard. The key VSME principles reflected in the platform:

Proportionality

Data entry is limited to sources that are material for the majority of SMEs. Highly technical or data-intensive sources (e.g. Scope 3 Cat. 1 purchased goods) are deferred to Phase 3 to avoid overwhelming small companies on first engagement.

Interoperability

Report format designed to be directly usable by buyers for ESRS E1 Scope 3 disclosures without reformatting. The tCO₂e figures map directly to ESRS E1-6 disclosure fields.

Reliability

Country-specific emission factors from authoritative national databases, not generic global averages. Factor sources and update dates cited on every report.

Accessibility

Plain-language tooltips and "how to find this number" guidance on every data entry field, designed for SMEs without a sustainability team.

5. What Remains the Buyer's Responsibility

Important — please read before using supplier data in CSRD filings.

VSME OS supplier reports satisfy the data collection requirement for Scope 3. They do not remove the buyer's obligation to:

  • Apply their own data quality assessment to supplier-submitted data before including it in regulated disclosures
  • Determine whether limited assurance (self-attested) is sufficient for their specific CSRD filing, or whether independently verified data is required
  • Aggregate supplier data correctly into the right Scope 3 categories (typically Cat. 1 for purchased goods/services, Cat. 11 for use of sold products)
  • Conduct spend-based or hybrid estimation for suppliers who have not yet submitted VSME OS reports
  • Disclose data quality and coverage gaps in their own CSRD filing
  • Ensure their assurance provider accepts self-attested supplier data (most do, but confirm with your provider)

Need a compliance briefing for your ESG team?

We can walk your sustainability or legal team through how VSME OS data integrates with your CSRD reporting workflow.