European Commission unveils revised draft simplified ESRS and VSME standard

 European Commission unveils revised draft simplified ESRS and VSME standard
  • Publication
  • 5 minute read
  • May 06, 2026

Sustainability reporting requirements across Europe continue to evolve, with a growing emphasis on making disclosures more proportionate, decision‑useful, and practicable. On 6 May 2026, the European Commission published two closely linked developments that respond directly to these objectives, being a revised draft of the simplified European Sustainability Reporting Standards (‘ESRS’) and a finalised Voluntary Sustainability Reporting Standard (‘VSME’) for smaller undertakings.

Instead of reshaping sustainability reporting requirements, the Commission has prioritised clearer, more proportionate application of existing standards. The result is a clearer framework that reduces interpretative risk, limits unnecessary complexity, and provides greater certainty to both reporters and users of sustainability information. While the two standards serve different audiences, with the ESRS applying to large in-scope undertakings under the CSRD and the VSME providing a proportionate framework for smaller companies, they have been calibrated to function together, ensuring consistency across the reporting chain. The VSME also acts as a value chain cap, shaping the information CSRD reporters can request from suppliers and supporting financial institutions in their own regulatory reporting. Despite this shared direction, the changes introduced under each standard differ in focus, reflecting the distinct reporting challenges faced by large undertakings and smaller companies. 

The following sections outline the main changes introduced under the revised simplified ESRS and the VSME. 

[1] Following the Omnibus I Directive, the CSRD applies to large undertakings with more than 1,000 employees and a net turnover above EUR 450 million.

Revised simplified ESRS Targeted clarifications for practical application

The Commission's revisions to EFRAG's draft of the simplified ESRS focus on clarity, proportionality, and legal certainty, rather than altering the overall direction of the simplification exercise. The most notable adjustments include:

The revised draft makes it explicit that undertakings shall not report non-material information. It also formally endorses a top-down approach to materiality, allowing undertakings to avoid assessing the materiality of every individual impact, risk, or opportunity, and instead focus on those most significant to the business as a whole.

Undertakings have been given greater discretion regarding geographical disaggregation in materiality assessments. Importantly, the level of disaggregation adopted in the materiality assessment does not imply that information must be reported at that same level of disaggregation.

Disclosures relating to anticipated financial effects are expected to rely on estimates, which may be updated over time in light of new information without constituting a prior period error. The provisions allowing the omission of information that could be seriously prejudicial to the undertaking's commercial position have also been clarified to extend to anticipated financial effects.

several targeted clarifications have been introduced across the topical standards, including:

  • Greater flexibility has been introduced in defining GHG reporting boundaries, with both the financial and operational control approaches now accepted.
  • Additional transparency requirements apply where climate transition plans are not aligned with a 1.5°C pathway.
  • Narrowing microplastics disclosures to primary microplastics only.
  • One year phase‑in relief for reporting on substances of very high concern.
  • Only “substantiated” incidents of human rights incidents and incidents of discrimination are to be report, being when it is evidenced by objective, factual, and verifiable information.

Taken together, these changes are designed to facilitate practical application, reduce interpretative risk and reinforce proportionality, while remaining fully aligned with the CSRD's underlying objectives. The result is a set of standards that is more workable for reporters, without compromising on the integrity of the information ultimately disclosed.

VSME A clearer, more proportionate framework for smaller undertakings

The VSME has been upgraded from a non-binding Commission Recommendation to a binding Delegated Regulation, directly applicable across all Member States. A new statutory value chain cap (Annex II) sets out the specific disclosures that large CSRD-reporting companies are permitted to request from suppliers with 1,000 employees or fewer. Suppliers gain a statutory right to refuse information requests that go beyond this cap, providing meaningful protection from disproportionate demands.

The overall number of datapoints has been reduced compared to the original VSME, with terminology and methodology tightened to ensure consistency with the revised simplified ESRS applicable to large reporters. This alignment supports a smoother flow of information through the value chain.

Each datapoint now carries a tag indicating the extent to which it’s mandatory, ranging from necessary disclosures through to voluntary ones. These tags determine which disclosures fall within the value chain cap and which remain optional. Where a disclosure is tagged as applying only in certain circumstances, omitting it is treated as confirmation that the disclosure does not apply to the undertaking, removing the need for companies to justify or explain non-applicable omissions.

A number of specific disclosures have been refined, including:

  •  Removal of the GHG intensity ratio.
  • Simplification of the biodiversity disclosure, which now only requires the name of the biodiversity-sensitive area, rather than the number of sites and hectares or square metres.
  • Removal of the EU Paris-aligned benchmarks exclusion previously captured under.
  • The gender pay gap disclosure is only required where the undertaking is already obliged to report it under EU law or other national regulations, and the training disclosure are no longer required to be split by gender.

A new appendix provides a mapping between VSME disclosures and the SFDR, CRR/Pillar 3 and the Benchmark Regulation, helping banks and investors use VSME data for their own regulatory reporting.

Overall, the Commission's changes preserve continuity with the original VSME, reinforce proportionality for the smallest undertakings, and ensure the standard functions effectively as the statutory value chain cap. The draft strikes a careful balance between providing smaller companies with a credible, structured reporting framework and protecting them from disproportionate information requests further up the value chain.

A step toward streamlined EU sustainability reporting

Looking ahead, both Delegated Regulations are expected to apply for financial years beginning on or after 1 January 2027, with earlier voluntary application possible under each. CSRD reporters may choose to apply the revised ESRS for financial year 2026 instead of the current standards, while the VSME will be available for voluntary use by smaller undertakings immediately upon entry into force.

As Delegated Regulations, both will be directly applicable in all Member States, without the need for national transposition. Together, they signal a clear commitment from the Commission to a more practical, proportionate and consistent sustainability reporting framework across the EU, one that works for reporters and users of sustainability information alike.

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