VSME Module B: Basic Disclosures
VSME Module B is the foundational level of VSME reporting — covering the minimum sustainability data set that large CSRD customers need from their SME suppliers. It is designed to be completable within a few weeks by a company with no dedicated sustainability function. Here is exactly what Module B requires and how to collect the data.
VSME Module B is the foundational level of VSME reporting — covering the minimum sustainability data set that large CSRD customers need from their SME suppliers. VSME Module B covers four disclosure areas:.
Module B content — what you must disclose
VSME Module B covers four disclosure areas:
General information: Company name, legal form, registered address, sector (NACE code), number of employees (full-time equivalent), annual turnover, and a brief description of the business model and main products or services. This contextual information allows customers and other stakeholders to interpret the sustainability metrics in the context of the company's size and activities.
Environmental metrics: — Total energy consumption in MWh, split by fossil fuel and renewable sources — Total Scope 1 GHG emissions in tonnes CO2e — Total Scope 2 GHG emissions (location-based) in tonnes CO2e — Total waste generated in tonnes, split by hazardous and non-hazardous — A statement on whether the company has significant water or biodiversity impacts
Social metrics: — Total number of employees by gender — Employee turnover rate — Number of work-related accidents resulting in injury — Number of days lost due to work-related accidents — Percentage of employees who received training in the reporting year — A statement confirming no forced labour and no child labour in operations
Governance: — Whether the company has an anti-corruption and anti-bribery policy — Whether the company has a supplier code of conduct — Whether the company has a whistleblower/complaints mechanism
Collecting Module B data — practical guidance
GHG emissions (Scope 1 and 2): For most SMEs, Scope 1 comes from gas boilers, company vehicles, and backup generators. Scope 2 comes from purchased electricity. Data sources: gas bills (cubic metres × gas emission factor), fuel receipts (litres × fuel emission factor), and electricity bills (kWh × grid emission factor). Use DEFRA 2025 GHG Conversion Factors — free download from the UK government website.
Energy consumption: Extract from utility bills — electricity (kWh), gas (kWh or m³ converted to kWh), and fuel (litres converted to kWh using calorific values). Total energy = sum of all fuel and electricity consumption in MWh.
Waste: Request annual waste summary reports from your waste contractor — most contractors provide this free of charge. The report will show total tonnes collected by waste type and disposal route. If your contractor cannot provide this, use your waste collection frequency × estimated container weight.
Employee metrics: Extract from your HR or payroll system — headcount by gender, joiners and leavers for turnover rate calculation. Health and safety incident data from your accident book or H&S management system.
Training hours: Extract from your training records or LMS (Learning Management System). If training is informal or undocumented, use a simple log of training activities with estimated durations during the year.
Governance statements: Review your company policy documentation — if you have an anti-corruption policy, supplier code, and a way for employees to raise concerns (even informally), you can answer yes to the governance questions.
Module B and customer ESG questionnaires
The primary practical benefit of VSME Module B for SMEs is the ability to point customers to a single standardised disclosure rather than completing multiple bespoke questionnaires.
How it works in practice: Publish your VSME Module B disclosure on your company website or provide it as a PDF to customers on request. When customers send ESG questionnaires, respond by pointing to your VSME disclosure and highlighting which sections answer which questions.
Mapping VSME to common questionnaires: CDP Supply Chain questionnaire — VSME Module B GHG and energy data satisfies the core CDP Supply Chain data requirements. EcoVadis assessment — VSME Module B environmental, social, and governance disclosures provide the evidence base for EcoVadis scoring. Sedex SMETA — VSME Module B social disclosures (no forced labour, no child labour, health and safety) align with SMETA labour standards assessment. Customer-specific questionnaires — most large company ESG supplier questionnaires request a subset of VSME Module B data.
For SMEs receiving multiple customer questionnaires: keep a master VSME Module B data spreadsheet updated annually. When questionnaires arrive, extract the relevant data points from the master spreadsheet rather than recollecting data for each customer. This reduces annual ESG reporting workload from weeks to hours after the initial setup.
Frequently asked questions
How long does it take to complete VSME Module B for the first time?
First-time data collection typically takes 2–4 weeks for a company with 50–250 employees and no existing ESG data infrastructure. The main time investments are: gathering utility bills and calculating GHG emissions (3–5 days); extracting HR metrics from payroll or HR system (1–2 days); obtaining waste data from contractor (1 day); and documenting governance (1 day). In subsequent years, updating the previous year's data takes 2–5 days.
Do we need to hire a sustainability consultant to complete VSME Module B?
No — Module B is designed to be self-completable by an SME without specialist sustainability expertise. The data required is straightforward operational data that most companies already collect for other purposes (utility bills, payroll data, waste contractor records). Free resources — DEFRA emission factors, this guide — provide the methodology guidance needed.
Can we use VSME Module B data in our marketing and communications?
Yes — VSME disclosures can be referenced in customer communications, tenders, and marketing materials. However, be careful not to overclaim — if you have disclosed Scope 1 and 2 emissions but not Scope 3, do not claim to be net zero or carbon neutral based on Module B data alone. The EU Green Claims Directive applies to environmental claims in marketing.