FAQCSRDSMEs

EU CSRD and ESRS LSME and VSME reporting for SMEs

and originated as different SME reporting tracks, but Directive (EU) 2026/470 materially changed mandatory CSRD scope and the legal basis for a voluntary standard.

This FAQ separates the original listed-SME route from the amended 2027 scope, the current Recommendation, and the and value-chain cap.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

The original Corporate Sustainability Reporting Directive (CSRD) included standards for listed small and medium-sized undertakings (), excluding micro-undertakings. Directive (EU) 2026/470 removed listed-SME status as a standalone scope trigger from financial years beginning in 2027 and limited the main mandatory scope to undertakings and parent groups exceeding EUR 450 million net turnover and an average of 1,000 employees. The Voluntary Sustainability Reporting Standard for SMEs () remains available under Commission Recommendation (EU) 2025/1710. The Commission also adopted a separate on 3 July 2026; its application and legal status should be checked against the final Official Journal publication.

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4 of 4 questions
Question 1

What is the difference between LSME and VSME under the EU CSRD?

was the original CSRD track for small and medium-sized undertakings, except micro-undertakings, whose securities were admitted to trading on an EU regulated market. The original framework allowed those undertakings to report specified SME information under proportionate standards. Directive (EU) 2026/470 removed listed-SME status as a standalone trigger from financial years beginning in 2027, so LSME now describes the earlier framework rather than a current route for every listed SME.

is voluntary. Commission Recommendation (EU) 2025/1710 gives undertakings outside mandatory CSRD reporting a proportionate format for answering sustainability information requests. It is distinct from the that the Commission adopted on 3 July 2026.

  • Use material to understand the original listed-SME framework, not as proof that a listed SME remains in scope after the 2026 amendment.
  • Use when the company is outside mandatory CSRD reporting and wants a voluntary, proportionate response format for sustainability data requests.
  • Run the amended turnover-and-employee test separately; listing status alone no longer supplies the main 2027 scope trigger.
Recommended next step

Separate mandatory CSRD reporting from voluntary SME responses

Record the amended mandatory-scope conclusion, preserve any historical listed-SME analysis, and choose the applicable voluntary standard for sustainability information requests.

Question 2

When does the CSRD listed-SME opt-out matter?

The opt-out is part of the original listed-SME framework. The 2022 CSRD text allowed relevant small and medium-sized public-interest undertakings, for financial years starting before 1 January 2028, not to include sustainability information in the management report if they briefly explained why.

Do not apply that historical rule without the later amendments. Directive (EU) 2025/794 postponed the listed-SME application date, and Directive (EU) 2026/470 then removed listed-SME status as a standalone scope trigger from 2027. A current conclusion must use the amended thresholds and applicable national law.

  • Keep the original opt-out only as legal history in the entity's scope record.
  • Apply the Stop-the-Clock Directive and Directive (EU) 2026/470 before deciding whether any reporting duty remains.
  • Record the reporting year, amended thresholds, national implementation, and legal source for the final conclusion.
Question 3

How should a non-listed SME use VSME in practice?

A non-listed SME should use as a voluntary response framework, not as a new mandatory CSRD obligation. The Commission says the voluntary standard is intended to reduce administrative burden by helping SMEs respond to sustainability information requests from large companies and financial institutions that are themselves subject to mandatory CSRD reporting.

Choose the module before collecting data. Under Commission Recommendation (EU) 2025/1710, the Basic Module contains B1 to B11 and covers general information plus environmental, social and business-conduct metrics. The Comprehensive Module adds information commonly requested by banks, investors and corporate customers and can be used only with the Basic Module. Once selected, a module is applied in full, while individual disclosures are provided only when they apply to the undertaking's circumstances.

Use the chosen module to standardize the SME's answers, keep repeatable evidence behind them, and avoid bespoke questionnaires expanding beyond what is proportionate for an SME. The Commission also encourages large companies and financial institutions seeking sustainability information from SMEs to base requests on the voluntary standard as far as possible.

  • Map incoming sustainability questionnaires to topics before creating custom answers.
  • Record whether the report uses the Basic Module alone or the Basic and Comprehensive Modules, whether it is individual or consolidated, the subsidiaries covered, the reporting period, and any disclosure omitted as classified or sensitive.
  • Keep the source request, the response, the evidence owner, and any unavailable-data explanation together.
  • Flag requests that appear to exceed the chosen voluntary standard for commercial or legal review. Check separately whether the Article 29ca value-chain cap applies to the request and reporting year.
Question 4

What should teams avoid when deciding between LSME and VSME?

Do not mix the two tracks. For a financial year governed by the original listed-SME transition, a listed SME needs a scope analysis covering the temporary opt-out and the standards then applicable. For financial years beginning in 2027, apply Directive (EU) 2026/470 instead: listing status alone is no longer a scope trigger. A non-listed SME outside mandatory scope usually needs a voluntary reporting and customer-request strategy, not a statement that CSRD directly applies to it.

Do not treat Commission Recommendation (EU) 2025/1710, an EFRAG draft, and the Article 29ca delegated standard as interchangeable. The Commission adopted C(2026) 5011 final on 3 July 2026. Confirm the delegated regulation's scrutiny, Official Journal publication, entry into force, and applicable annex before treating it as the controlling standard.

  • Do not cite as mandatory CSRD reporting for every SME.
  • Do not rely on an opt-out without confirming listed-SME status and the required management-report explanation.
  • Do not promise a final or future voluntary-standard position unless the current legal source supports it.
Primary sources

References and citations

ec.europa.eu4 citations
Referenced sections
  • Commission context distinguishing listed-SME reporting from voluntary non-listed SME standards and value-chain safeguards.
  • Explains that the Accounting Directive as amended by CSRD imposes no new reporting requirements on SMEs except listed SMEs.
  • Provides Commission context that listed SMEs may opt out for a further two years after the initial listed-SME reporting start.
Show 1 more
  • Supports this page's separating listed-SME reporting from non-listed SME voluntary reporting analysis under the CSRD framework.
"no new reporting requirements on SMEs, except listed SMEs"
More quoted passages
"imposes no new reporting requirements on SMEs, except listed SMEs"
"listed SMEs may decide to opt out"
"separate, proportionate standards"
finance.ec.europa.eu3 citations
Referenced sections
  • Commission source for VSME due process, support materials, value-chain cap context, and possible differences from any future delegated act.
  • Supports the Commission's context that VSME can replace a substantial portion of recurring bank and large-undertaking information requests.
  • Supports caution that a future voluntary standard may differ from the current VSME Recommendation.
"future voluntary reporting standard might differ"
More quoted passages
"a credible replacement for a substantial portion of information requests"
"might differ from the current VSME Recommendation"
finance.ec.europa.eu3 citations
Referenced sections
  • Commission source for the VSME Recommendation and its purpose in easing SME responses to CSRD-related information requests.
  • Supports the VSME context for voluntary reporting by SMEs responding to CSRD-related value-chain information requests.
  • Supports using VSME to answer sustainability information requests from CSRD-reporting large companies and financial institutions.
"voluntary standard for SMEs (VSME)"
More quoted passages
"voluntary sustainability reporting for small and medium-sized companies"
"making it easier for them to respond to requests"
eur-lex.europa.eu3 citations
Referenced sections
  • Primary legal text for listed-SME CSRD scope, the SME reporting derogation, and the temporary opt-out explanation requirement.
  • Supports the listed-SME scope rule, the exclusion of micro-undertakings, and the SME reporting derogation in the CSRD amendments.
  • Supports the temporary opt-out for listed SMEs and the requirement to explain why sustainability reporting was not provided.
"small and medium-sized undertakings, except micro undertakings"
More quoted passages
"briefly state in its management report why the sustainability reporting was not provided"
eur-lex.europa.eu
Referenced sections
  • Defines the Basic and Comprehensive Modules, the prerequisite relationship between them, module-completeness rule, applicability condition, and basis-for-preparation fields.
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