CSRD vs VSME: Which framework applies to you in 2026?

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With almost three-quarters of shippers (72%) using ESG goals as part of their RFP processes and countries introducing ambitious emissions reduction targets, sustainability has never been more important for shippers and their transport and logistics partners. 

To get companies to start measuring and reporting on their sustainability performance, the EU has introduced a raft of sustainability regulations over the past few years. These include the Corporate Sustainability Reporting Directive (CSRD) and the voluntary sustainability reporting standard (VSME). 

In this article, we’ll explain how to figure out whether the CSRD or the VSME is more relevant to your operations, and give you advice on how (and why) to align with them. 

What is the difference between CSRD and VSME—and how do you know which is relevant for your company?

The main difference between CSRD and VSME is that the CSRD requires mandatory reporting for companies that fall within its scope, whereas the VSME is a voluntary standard that simplifies sustainability reporting for smaller companies.  

What is CSRD?

The Corporate Sustainability Reporting Directive (CSRD) is a directive that requires certain companies to report on how they impact the environment, and which climate and ESG risks may affect their business. It was proposed in 2021 to replace the (NFRD) Non-Financial Reporting Directive and extend reporting obligations to companies that previously didn’t have to publish sustainability-related reports. 

The CSRD is being rolled out in several waves, with wave 1 (companies that were already subject to the NFRD) reporting under CSRD since 2025. Following the Omnibus I package which aimed to simplify reporting for companies, Wave 2 will now apply to EU and certain non-EU companies who meet higher revenue (€450m) and headcount (1,000 employees) thresholds than originally planned, with the first reporting year in 2028. 

What is VSME?

The VSME is a voluntary standard that aims to simplify how non-listed small and mid-sized companies not in the scope of CSRD provide sustainability data to their larger clients, supply chain partners, investors, or even financial institutions. It was developed by EFRAG and is strongly endorsed by the EU for use by small and mid-sized companies across the region.

The VSME Standard was approved in late 2024, and is split into two modules that comprise different environmental, social and governance metrics:

• Basic Module: this is the target approach for micro-companies and constitutes a minimum requirement for SMEs. 
• Comprehensive Module: this goes above and beyond the data points in the Basic Module by including additional metrics which are likely to be requested by banks, investors and corporate clients of a company.  

By its nature, the VSME is a voluntary standard so it is not mandatory for companies of any size. However, with 56% of shippers saying that they are prepared to terminate contracts if sustainability objectives are not achieved, it is debatable whether the standard is really voluntary. EFRAG regularly publishes new templates and resources to help companies start reporting in line with the VSME.

How the EU’s Omnibus I package changed CSRD reporting requirements 

The Omnibus packages aimed to simplify and clarify sustainability reporting obligations by postponing and amending the reporting thresholds for several EU sustainability-related directives, including the CSRD. 

It took nearly a year of negotiations, but it was adopted in February 2026, increasing the thresholds under the CSRD and shifting the first reporting year for wave 2 companies to 2028. It also led to a “quick fix” to clarify reporting requirements for wave 1 companies in the transition period. 

The Omnibus also seeks to prevent large enterprises from requiring suppliers to provide excessive sustainability information, but these enterprises can (and will) ask for data that’s covered by voluntary standards like the VSME.

Timeline of CSRD

The CSRD scope has changed a lot since it was first proposed in April 2021. Here is a summary of the main milestones relevant to the CSRD:

• April 2021: Proposal of the CSRD as a replacement to the NFRD
• December 2022: CSRD published in OJEU
• December 2023: European sustainability reporting standards published in OJEU
• February 2025: Proposal of Omnibus I package to simplify CSRD reporting
• April 2025: Political agreement on ‘Stop-the-clock’, delaying CSRD reporting
• July 2025: Adoption of a “quick‑fix” delegated act to revise the first set of ESRS
• December 2025: Political agreement on Omnibus I
• Now: CSRD in force, with wave 2 companies reporting in 2028

With all these changes, many companies are unsure how the CSRD impacts them now and in the future, which is why we’ll now walk through how to figure out if the CSRD applies to your company.

Determining if CSRD applies to your company

The CSRD applies to a broader range of companies than the previous NFRD did, including some that aren’t even based in the EU. In addition to the companies who already reported under the NFRD (i.e. CSRD wave 1 companies) and following the Omnibus I package, the CSRD now applies to companies with:

• €450 million net turnover [applies to non-EU companies too]
• More than 1,000 employees 

These wave 2 companies are required to publish their first CSRD report (aligned with ESRS standards) in 2028 for the previous financial year.

How to prepare for CSRD reporting if you meet these thresholds 

Even though it may seem that the reporting deadlines are likely to be a few years away (or 2028 to be specific), there are plenty of things you should be starting now to avoid a stressful, resource-intensive first reporting cycle. This includes: 

1. Appoint a CSRD Lead: select someone who will lead CSRD for your company, and loop in relevant personnel who can support with data gathering and reporting. 
2. Get familiar with the ESRS: the ESRS provide guidance on the actual data points and information you’ll need to include in your reports. 
3. Map your supply chain and identify high-risk areas: evaluate your current value chain and figure out what activities hold the most risk of harming the environment. 
4. Decide how you’ll collect and consolidate sustainability data: explore your options for accurately and efficiently gathering data (tools like carbon accounting software make this quicker, more transparent, and more accurate).
5. Conduct a double materiality assessment: carry out a DMA to understand how your business impacts people and the planet (‘impact materiality’), and how sustainability risks affect your business (‘financial materiality’).

It may seem daunting to start preparing for the CSRD, but by taking a step-by-step approach, you can get prepared in time, and you may even see some benefits in the meantime. 

Outside the CSRD scope? VSME should be your next step

With the Omnibus I package now officially in force, around 80% of companies previously within the CSRD scope are no longer subject to mandatory sustainability reporting. But that doesn't mean sustainability reporting is going away—and that's exactly where the VSME comes in.

The European Commission officially endorsed the VSME in July 2025 as the recommended reporting framework for companies outside the CSRD scope, and it's on track to become a formal delegated act later in 2026. This means VSME is becoming the EU's de facto sustainability reporting standard for smaller companies.

The VSME’s  metrics range from energy and greenhouse gas emissions to climate risk mitigation measures to the gender balance ratio. The VSME guidance document walks companies through each metric in detail so we recommend checking that out. 

Crucially, the VSME is also now linked to the Omnibus I "value chain cap" which limits what large, CSRD-bound companies can request from their suppliers and partners. Aligning with VSME effectively defines and protects the ceiling of data requests you'll receive from your larger customers.

But before investing time and resources into following the VSME, you may be interested in knowing the other business benefits of doing so:

1. Gain a competitive advantage in tenders

Most purchasers are now including sustainability metrics in their tender eligibility and scoring criteria, especially large corporations and public sector organizations. By adopting the VSME standard, companies can report on their sustainability performance in a standardized format that is easily understandable and comparable by the purchasing entity. 

This leads to higher scoring in sustainability categories, and thus a greater chance of winning the contract. Proactively using the VSME also makes securing certifications like the CDP or the CO₂ Performance Ladder a whole lot easier. 

2. Retain existing clients

Following the VSME also helps retain your existing clients by standardizing the data points you share with clients, which simplifies their own reporting preparations. It also demonstrates your commitment to measuring and reducing your environmental impact, helping strengthen your brand’s reputation as a leader in sustainability, which in turn builds customer loyalty.    

3. Improve access to green financing 

Banks and investors are increasingly considering ESG (Environmental, Social, and Governance) factors in their decision-making processes. By aligning with the VSME standard, SMEs can provide standardized ESG data, potentially improving their access to financing and favorable loan conditions. 

4. Reduce your carbon footprint and costs 

Regularly reviewing and reporting on sustainability metrics helps you identify opportunities to improve your performance. These can be quick-win initiatives like switching electricity suppliers, or more substantial changes like replacing your diesel vehicles with electric vehicles. And the good news is that by reducing your carbon footprint, you often also reduce your costs. Common cost savings include lower energy costs and avoided carbon taxes.  

5. Stepping stone for future compliance requirements 

While sustainability reporting requirements have been simplified for many companies with the Omnibus packages, it’s still likely that these companies may have to report in the future. This could be because they grow, the reporting criteria changes, or new regulatory requirements are introduced. Either way, following the VSME is a great stepping stone for companies to get started with sustainability reporting so they’re prepared for whatever comes down the line. 

Where the ESRS fits into your reporting, whether you’re under the CSRD or VSME 

The European Sustainability Reporting Standards (ESRS) are the official reporting standards that define what companies need to report under the CSRD. Think of them as the rulebook that explains which data points you need to disclose, how to structure them, and what level of detail is expected for CSRD-bound companies.

There are currently 12 ESRS standards covering environmental, social, and governance topics, though a simplified, reduced set is on the way once the Commission adopts EFRAG’s revised technical advice (deadline is September 2026). The standards are aligned with the approach of the International Sustainability Standards Board (ISSB) and the Global Reporting Initiative (GRI) to maintain consistency between EU and global standards.

If your business involves transport and logistics activities, some of the most relevant ESRS topics will likely include:

• Greenhouse gas emissions (Scope 1, 2, and 3)
• Energy use and efficiency
• Pollution and waste management
• Working conditions and human rights across your supply chain

And if you’re out of scope of the CSRD, then the ESRS is still relevant for you, as the VSME is designed to align with the ESRS, but just with less complexity. That means if you’re using the VSME today and are required to report under the CSRD at a future date, you’ll already be well prepared for most of the ESRS topics. 

How carbon accounting software simplifies CSRD and VSME reporting

If you’re getting started with the CSRD or the VSME, then solutions like BigMile’s carbon accounting software make collecting, analyzing, and reporting on your data much easier, faster, and more accurate. 

Our carbon accounting software can help you easily track, calculate, and report emissions while ensuring full alignment with leading industry standards like the GLEC Framework, ISO 14064, and ISO 14083. 

Transport and logistics companies like De Rijke Group are using BigMile to become leaders in sustainability and win new business, as Martijn Scheffers explains: 

“We are among the top 3% worldwide in terms of sustainability assessments. And that's also because we have our CO2 management well in order now. So, where we initially stood at zero, we have quickly developed a very robust CO2 framework. We can now map everything out accurately thanks to BigMile’s platform.” 

Want to learn more about how we can help you monitor your emissions to support compliance with the CSRD or alignment with the VSME? Book a call with one of our experts.