What VSME actually requires of a Swiss SME.
An EU customer asked for "VSME-aligned data" last week. This note translates the request into a concrete shopping list, with one worked diesel-delivery line item from invoice to factor to result.
investor-data-room/NOTES-OUTLINES.md.
Where this note starts.
A Swiss CFO at a 200-person manufacturer received an email from an EU automotive customer last week: "Please complete the attached VSME data request by 30 September." The attachment was a spreadsheet with sixty-three rows of energy and emissions questions. The CFO does not file an annual sustainability report. The CFO has never heard of EFRAG. The CFO has two weeks. This note is for that CFO.
What VSME actually is.
The Voluntary SME standard is the European Financial Reporting Advisory Group's reporting template for companies that fall outside the mandatory CSRD/ESRS scope but receive sustainability data requests from EU customers, banks or investors. EFRAG published the final standard on 17 December 2024 (EFRAG VSME page). The Omnibus I directive of February 2026 (EUR-Lex) capped the value-chain information that in-scope CSRD filers may demand from suppliers under 1,000 FTE at VSME scope. That cap made VSME the de facto ceiling for what an EU-customer-facing SME has to answer.
The standard has two halves. The Basic Module (B1–B11) covers the minimum: basis of preparation, sustainability practices, energy and GHG (B3), pollution, biodiversity, water, resources and waste, workforce, business conduct. The Comprehensive Module (C1–C9) adds strategic context, Scope 3 emissions by category, and several governance items requested by the largest customers and capital-markets analysts.
cobank's voluntary tier addresses the emissions and energy datapoints — B3 (GHG and energy) and C2 (Scope 3 by category). It does not address the workforce, water, biodiversity or governance modules. That scope decision is explicit in every export the product produces; the coverage statement on the disclosure names exactly what is and is not covered, so a reader cannot mistake one for the other.
The minimum data set for a credible answer.
A VSME response stands on four numbers.
- Scope 1. Direct emissions from owned or operationally-controlled sources. Mostly fuel combustion in owned vehicles, on-site heating boilers, and refrigerant leakage.
- Scope 2 — location-based. Purchased electricity and heat, valued at the local grid average. For Switzerland the headline factor is 0.109 kgCO₂e/kWh (BAFU 2025).
- Scope 2 — market-based. Purchased electricity and heat, valued at the supplier-specific instrument the buyer actually holds. Herkunftsnachweise and Guarantees of Origin show up at zero under this method; the location-based figure stays disclosed in parallel so a reader can see both.
- Scope 3. Value-chain emissions from purchased goods and services, upstream transport, business travel, waste and employee commuting.
The Comprehensive Module (C2) asks for Scope 3 split by category. The five categories that show up in most actual VSME data requests are Category 1 (purchased goods and services), Category 3 (fuel- and energy-related activities not in Scope 1 or 2), Category 5 (waste generated in operations), Category 6 (business travel) and Category 7 (employee commuting). They cover the spend a finance team can produce evidence for without commissioning a bottom-up product-LCA exercise.
One worked line item.
A diesel-delivery invoice from a Swiss freight vendor lists 1'240 litres of diesel pumped into the delivery-van fleet in March. The line classifies to mobile_combustion (a Scope 1 category — the company controls the vans). The factor is DEFRA 2025 diesel_transport at 2.65 kgCO₂e/litre (DEFRA conversion factors).
1'240 L × 2.65 kgCO₂e/L = 3'286 kgCO₂e
That single line contributes 3.286 tCO₂e to Scope 1 for the period, with the factor version (DEFRA 2025) pinned next to the number so a reviewer can trace it back to source. Sixty-three rows answered consistently are what a VSME response looks like when the underlying data is invoice-level instead of spreadsheet-aggregated.
What VSME does not require.
- Third-party assurance is voluntary. A VSME report is a self-declaration. The customer can ask for assurance separately; most do not in the first year.
- Reasonable assurance is not on the table. Where a customer or bank asks for assurance over a VSME-shaped disclosure, ISSA 5000 limited assurance is the ceiling (IAASB ISSA 5000). Reasonable assurance is the higher bar reserved for CSRD/ESRS-in-scope filers.
- No statutory filing in Switzerland for most respondents. Swiss Code of Obligations Art. 964a–c (admin.ch) applies to public-interest companies above defined size thresholds. Most VSME respondents are below those thresholds and have no Swiss statutory filing obligation; they answer the customer's request directly, not through an annual report.
- No prescribed software. Spreadsheets are the dominant tool. The standard cares about defensible numbers and a documented basis, not the system that produces them.
What customers do increasingly ask for, alongside the numbers, is a one-page "basis of preparation" that names which legal entities are in scope, which consolidation method (operational control, financial control or equity share) the totals roll up under, and which emission factors were used in which version. That single page is what differentiates a useful answer from a spreadsheet someone will email back with follow-up questions.
cobank's role.
cobank produces the VSME-shaped artifact and the workpaper trail underneath it. Every invoice line is classified to a GHG Protocol category, multiplied by a versioned emission factor, and totalled into the four scope numbers above. The export bundles a JSON disclosure (basis of preparation, GHG by scope, Scope 3 by category, energy in MWh, methodology), a PDF formatted for a customer or bank, and an Excel workbook with the per-line evidence the auditor or buyer can re-perform against.
A first VSME response that previously cost a finance team two weeks of spreadsheet wrangling produces in a day from the invoice ledger. The customer's question gets answered, the factor versions and the per-line audit trail are visible to anyone the company chooses to share the export with, and the same period locks into a snapshot that can be re-issued next year against a year-on-year comparison without reopening the maths.
The standard is one piece. The infrastructure to produce defensible numbers against it is the harder piece. That is the piece cobank handles. The VSME emissions disclosure is exported from the Reports view — pick the output format toggle, then preview, PDF, or Excel.