Even if many companies are relieved of their reporting obligations by the EU Omnibus Initiative, the requirements of the market remain: Sustainability data is still a key consideration for customers, banks, investors and funding bodies.
This is precisely where the Voluntary Standard (VS) comes in: The standard developed by the EU offers companies with an average of no more than 1,000 employees that choose to report voluntarily a practical framework for compiling and effectively communicating their sustainability data.
What are the real benefits of the Voluntary Standard? In this blog article, we demonstrate which sustainability information is covered by the VS, which modules it consists of and why large companies are also increasingly turning to this standard.
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With the delegated act adopted on 3 July 2026, the European Commission established a standard for voluntary sustainability reporting. The Delegated Regulation was published in all official EU languages in the Official Journal of the European Union on 21 September 2026. In terms of content, the Voluntary Standard builds on the recommendation for a “Voluntary Sustainability Reporting Standard for Small and Medium-sized Undertakings” (VSME) set out in Recommendation (EU) 2025/1710 of 30 July 2025. |
Medium-sized companies are increasingly confronted with ESG (Environmental, Social, Governance) requests from business partners, banks and investors. They often have to complete a wide range of questionnaires to provide sustainability information to their financial institutions and business partners subject to mandatory reporting requirements – a process that is often costly and inefficient.
The Voluntary Standard is designed to remedy this by:
Standardising sustainability data – providing a clear structure for efficient reporting
Enhancing future readiness – preparing companies at an early stage for increasingly demanding regulatory requirements
Improving transparency – and thus strengthening trust among customers and business partners
The sustainability report is primarily intended to provide information to business partners and may be made publicly available on a voluntary basis. As a general rule, it is prepared annually and may be integrated into the management report, published as a separate document, or combined with the EMAS environmental statement. Cross-references to unchanged information or information published elsewhere can help avoid duplication of disclosures.
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Topics |
Sub-topics |
Number of data points |
|
General information |
B1 Basis for preparation |
12 |
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B2 Practices, policies and future initiatives for transitioning towards a more sustainable economy |
5 |
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Environment metrics |
B3 Energy and greenhouse gas emissions |
11 |
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B4 Pollution of air, water and soil |
1 |
|
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B5 Biodiversity |
6 |
|
|
B6 Water |
3 |
|
|
B7 Resource use, circular economy and waste management |
4 |
|
|
Social metrics |
B8 Workforce – General characteristics |
4 |
| B9 Workforce – Health and safety |
3 |
|
| B10 Workforce – Remuneration, collective bargaining and training |
4 |
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Governance metrics |
B11 Convictions and fines for corruption and bribery |
2 |
Companies seeking to meet more detailed information requests from external stakeholders can use the Comprehensive Module.
The disclosures are aligned with the statutory and regulatory requirements applicable to financial market participants and corporate clients. At the same time, they address the information needs of business partners seeking to assess a company’s sustainability risk profile, for example when considering it as a potential supplier or borrower.
The Comprehensive Module builds on the Basic Module and includes nine additional reporting topics. It provides further disclosures on the company’s business model and sustainability strategy, Scope 3 emissions, climate targets, and climate-related risks. It also covers workforce-related matters, human rights, the gender diversity ratio in the governance body, as well as revenue generated from certain controversial business activities.
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Topics |
Sub-topics |
Number of data points |
|
Basic Module |
(see above) |
55 |
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General information |
C1 Strategy: Business model and sustainability – Related initiatives |
4 |
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C2 Description of practices, policies and future initiatives for transitioning towards a more sustainable economy |
2 |
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Environment metrics |
C3 GHG reduction targets and climate transition |
7 |
| C4 Climate risks |
5 |
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Social metrics |
C5 Additional (general) workforce characteristics |
2 |
| C6 Additional own workforce information – Human rights policies and processes |
8 |
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| C7 Human rights incidents |
7 |
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Governance metrics |
C8 Revenues from certain activities |
5 |
| C9 Gender diversity ratio in the governance body |
1 |
The VS distinguishes between mandatory data points, voluntary disclosures and information that is required only under specific circumstances. For the latter, the so-called ‘if applicable’ principle applies: the relevant disclosure is required only if the circumstances specified in the disclosure requirement apply to the undertaking. If an undertaking omits such a disclosure, it is assumed that it does not apply.
As a general rule, a selected module must be applied in full. However, the ‘if applicable’ principle ensures that undertakings are only required to disclose information that applies to their particular circumstances. This allows the reporting requirements to be tailored to the undertaking’s individual situation.
The Basic Module always forms the foundation of the reporting. Therefore, the Comprehensive Module cannot be applied on a standalone basis and may only be used in addition to the Basic Module. In its report, the undertaking must specify which option it has chosen. It must also explicitly state that the report has been prepared in accordance with the Voluntary Standard and the selected reporting option.
Start collecting data early – document and structure existing sustainability measures
Use the Basic Module as a starting point – the Comprehensive Module can be added at a later stage
Use synergies – build on existing systems and frameworks such as EMAS or ISO 14001
Involve stakeholders – coordinate with business partners and financial institutions at an early stage
Benefit from funding programmes – obtain financial support for your sustainability initiatives (see below)
Under the German “Förderung von Unternehmensberatungen für KMU” funding programme (funding for management consultancy services for SMEs), sustainability-related issues may also be addressed, provided the consultancy is individually tailored and provides strategic guidance on business management. Eligible topics include, for example, first steps towards sustainability reporting, gap analyses, the development of ESG measures, or preparation for sustainability ratings such as EcoVadis.
Consultancy costs of up to €3,500 per consulting engagement are eligible for funding. As a general rule, the grant covers 50% of eligible costs, up to a maximum of €1,750. For companies located in the new federal states of Germany (excluding Berlin and the Leipzig region), as well as in the Lüneburg and Trier regions, the grant amounts to 80% of eligible costs, up to a maximum of €2,800. The current funding guideline is valid until 31 December 2026. During the funding period, companies may receive funding for a maximum of five consultancy assignments, with no more than two funded per year.
The BMWK also supports the creation of a transformation plan with a grant of up to €90,000 (funding rate up to 70%) for companies with a permanent establishment or branch in Germany. This is subsidised by BAFA in particular with Module 5 - Transformation Plans of the Federal Funding Scheme for Energy and Resource Efficiency in Economy (EEW). A transformation plan is a document setting out a company’s or site’s long-term decarbonisation strategy. It contains a qualitative and quantitative description of the initial situation in relation to a carbon reduction target as well as possible measures to achieve the target.
The 'Unternehmen machen Klimaschutz' corporate climate action programme of the Baden-Württemberg Ministry for the Environment, Climate and Energy Sector supports companies with a registered office or operational site in Baden-Württemberg in the implementation of climate protection measures. Companies receive financial support for consultancy services to prepare greenhouse gas inventories, develop transformation strategies and identify emission-reduction measures. The consultancy funding covers 75% of the consultancy costs (max. 900 euros net per consultant-day for up to 5 days). In addition, investments that result in a significant reduction or avoidance of greenhouse gases are subsidised. The investment grant covers up to 50% of eligible expenditure, up to a maximum of 80,000 euros.
Whether identifying relevant KPIs, collecting ESG data or setting up internal structures – efficient reporting requires planning and time. Starting early lays the foundation for a smooth reporting process and helps avoid additional work.
With extensive expertise in funding, innovation and sustainability, and as an official DNK Guide (‘DNK Lotse’), we provide practical support tailored to your specific needs. Our sustainability consultants look forward to assisting you. Feel free to get in touch.
(Header image: Freepik)