VSME Implementation Guide
Implementing VSME Module B does not require a sustainability consultant, a new software system, or months of preparation. Most SMEs can complete their first VSME Module B disclosure within 30 days using data they already have. Here is the step-by-step guide.
Implementing VSME Module B does not require a sustainability consultant, a new software system, or months of preparation. Day 1–2: Gather all utility bills for the reporting year — electricity, gas, and any other fuels (diesel, LPG, oil).
Week 1 — Collect energy and emissions data
Day 1–2: Gather all utility bills for the reporting year — electricity, gas, and any other fuels (diesel, LPG, oil). Organise by month and by site if you have multiple locations. Total up annual kWh (electricity) and m³ or kWh (gas).
Day 3: Calculate Scope 2 emissions from electricity. Multiply total kWh of electricity consumed by the grid emission factor for your country. UK companies: use DEFRA 2025 'UK electricity' conversion factor (search 'DEFRA GHG conversion factors 2025'). EU companies: use IEA or national grid factor for your country.
Day 4: Calculate Scope 1 emissions from gas and fuel combustion. Gas: multiply m³ consumed by gas emission factor (DEFRA: natural gas = 0.18 kg CO2e/kWh). Diesel: multiply litres by diesel emission factor (DEFRA: diesel = 2.51 kg CO2e/litre). Add Scope 1 from vehicles if company owns a fleet.
Day 5: Calculate total energy consumption. Sum all energy sources in MWh: electricity (kWh ÷ 1,000), gas (m³ × 10.55 kWh/m³ ÷ 1,000), diesel (litres × 10.7 kWh/litre ÷ 1,000). Categorise as fossil fuel (gas, diesel, petrol) or renewable (if you have solar or purchase renewable electricity with GOOs).
Week 2 — Collect social and waste data
Day 6–7: Extract HR metrics from payroll or HR system. You need: total headcount at year-end by gender (male/female/other); total number of new employees during the year; total number of employees who left during the year (for turnover rate = leavers ÷ average headcount × 100).
Day 8: Extract health and safety data from your accident book, H&S management system, or RIDDOR reports (UK). Count: number of work-related accidents resulting in injury (recordable incidents); total number of days lost due to work-related injuries across all employees.
Day 9: Extract training data. Count the number of employees who received at least one training session or course during the year. Divide by total headcount to get the percentage trained. If training is undocumented, create a simple training log retrospectively — ask managers to list training activities for their teams.
Day 10: Contact your waste contractor and request an annual waste summary report. This should show total tonnes collected by waste type and disposal method (landfill, recycling, incineration). If unavailable, estimate from your waste collection frequency and container sizes.
Week 3 and 4 — Complete governance, draft and publish
Day 11–12: Review your governance documents. Do you have an anti-corruption or anti-bribery policy? A supplier code of conduct? A way for employees to raise concerns (even an informal open-door policy counts as a basic mechanism)? Document yes/no for each with a brief description.
Day 13–14: Draft your general information section. Write 2–3 sentences describing your business model and main products or services. Note your NACE sector code (find at ec.europa.eu/eurostat/ramon/nomenclatures/index.cfm), total FTE employees, and annual turnover (from your financial statements).
Day 15–20: Compile all data into your VSME Module B report. Format options: a simple Word or PDF document with sections for each disclosure area; a dedicated page on your company website; or a structured data file provided to customers on request. There is no mandated format — choose whatever is practical for your business and your customers.
Day 21–25: Internal review. Ask your finance director or managing director to review the report for accuracy and reasonableness. Check that GHG figures look plausible relative to your energy costs and operations. Correct any errors.
Day 26–30: Publish and communicate. Upload the report to your website or prepare as a PDF. Email your key customer sustainability contacts to notify them of your VSME disclosure and provide a link or copy. Update your standard questionnaire response to reference the VSME disclosure.
Frequently asked questions
What if we do not have data for one of the Module B metrics?
Disclose what you have and note what is missing with an explanation. For example: 'Waste data for Q1 is unavailable as we changed waste contractors in March — full year data will be available in next year's report.' Partial disclosure is better than no disclosure. Customers and stakeholders appreciate transparency about data gaps more than silence.
Do we need to get the GHG calculation reviewed by an expert?
Not for VSME Module B — the calculations are straightforward (energy consumption × emission factor) and the methodology is free and publicly documented (DEFRA GHG Conversion Factors). For Module C Scope 3 calculations, a brief review by a sustainability consultant or accountant familiar with GHG Protocol methodology is useful but not required.
How do we update the VSME disclosure each year efficiently?
Keep a master VSME data spreadsheet that you update annually. Structure it with one row per metric and columns for each year — this gives you year-on-year comparison automatically. Set a calendar reminder in January to start collecting the previous year's data. Most of the data comes from annual utility bills, the waste contractor annual report, and year-end payroll data — all of which are available by February for a December year-end.