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      Swiss SMEs are increasingly asked to provide structured sustainability and ESG information – whether by large customers subject to CSRD, by banks assessing ESG risks, or by business partners and investors with growing transparency expectations.

      While many SMEs are not legally required to report under CSRD or Swiss Code of Obligations thresholds, sustainability reporting is becoming a de‑facto market expectation.

      Two frameworks are currently relevant for voluntary sustainability reporting by SMEs: the EFRAG Voluntary Sustainability Reporting Standard for SMEs (VSME) and the EU Commission’s Voluntary Sustainability Standard (VS).  The VS is based on EFRAG’s VSME Standard and was adopted and published by the European Commission as a final Delegated Regulation on 3 July 2026.

      While the VSME remains a voluntary reporting framework, the VS provides a legally binding  Value Chain Cap, limiting the sustainability information that CSRD-reporting companies may request from SMEs and other companies outside the CSRD scope.  

      The Delegated Regulation replaces the European Commission’s Recommendation on the VSME, published in July 2025, and encourages other market participants to use the VS dataset when requesting sustainability information from smaller companies.

      For Swiss SMEs, both frameworks provide a practical and proportionate basis for responding consistently to ESG data requests, strengthening stakeholder communication, and supporting future-ready sustainability management.

      Theresa Tiersch
      Theresa Tiersch

      Director, Corporate Sustainability Services

      KPMG Switzerland

      What is the Voluntary Sustainability Reporting standard?

      The Voluntary Sustainability Standard (VS) is a voluntary sustainability reporting framework designed for companies that are not subject to the CSRD.

      Published by the European Commission as a delegated regulation, the VS is based on EFRAG’s VSME framework and provides a practical, proportionate and internationally recognized approach to ESG reporting.

      It helps SMEs and other companies respond consistently to sustainability information requests from customers, banks, investors and other stakeholders, while limiting the sustainability data that CSRD-reporting companies may request through the value chain cap.

      The framework remains closely aligned with ESRS principles but is simplified to reflect the realities, resources and reporting needs of smaller businesses.

      Discover more

      The VS delegated regulation can be accessed here:  Corporate Sustainability Reporting Directive - Finance.

      Who should consider VS reporting?

      The VS is particularly relevant for: 

      • Companies not subject to CSRD/Swiss CO reporting requirements that still wish to report on their sustainability performance 
      • Companies within the supply chains of large, reporting‑obligated organizations needing to meet transparency requirements 
      • SMEs with stakeholders increasingly requesting sustainability information (e.g., investors, customers, business partners) 

      Why does VS matter for Swiss SMEs?

      Choosing to report under the VS is voluntary – but increasingly a strategic business decision.

      As sustainability information requests from customers, banks, investors and other business partners continue to grow, the VS provides a practical, proportionate and standardized framework that enables SMEs to respond consistently and efficiently.

       

      Download PDF

      Omnibus, CSRD & ESRS for SMEs: What Matters Now

      Overview of the latest Omnibus CSRD and ESRS updates for SMEs

      Download PDF
      • Continued ESG data requests from large customers (value‑chain pressure)

        Large companies subject to CSRD must collect ESG information from their suppliers, often through inconsistent, bespoke questionnaires. 

        The EU Omnibus framework introduced a “value chain cap”, meaning large companies should not request data from SMEs that go beyond the disclosures as of the comprehensive module of the standard. This cap provides SMEs with legal protection against excessive data requests.


        → The VS, in turn, gives SMEs a recognized, standardized format to respond efficiently to legitimate requests – reducing administrative burden and ensuring comparability across the value chain. 

      • Increasing relevance in banking and financing

        Banks and financial institutions increasingly assess ESG performance through structured questionnaires and scoring models. Lack of information can lead to weaker ESG ratings and can negatively influence financing conditions.

        → A VS-aligned report helps SMEs respond consistently to banking requirements and demonstrate proactive sustainability management. 

      • Rising stakeholder expectations

        Even in the absence of legal obligations, expectations for ESG transparency are growing across all stakeholder groups. 

        → VS helps SMEs build credibility, transparency and trust with partners, customers and talent that increasingly factor sustainability into their decisions. 

      • Preparing early for future regulatory developments

        EU sustainability regulations continue to evolve, and Switzerland is expected to align step‑by‑step with European frameworks. What is voluntary today may become mandatory tomorrow.

        → Early adoption of the VS helps SMEs build processes, data structures and internal responsibilities that support ongoing and potential future reporting needs. 

         

      What are the VS Basic and Comprehensive Modules?

      The VS consists of two modules: the Basic Module (B1–B11), covering fundamental disclosures across environmental, social and governance topics; and the Comprehensive Module (C1–C9), which adds deeper insights into strategy, climate targets, risks, human rights and governance. Companies may begin with the Basic Module and scale up as needed. 

      The VS sets out a defined set of ESG disclosure requirements covering core environmental, social and governance topics.

      The overview below highlights the main disclosure areas included under each module.

      How can companies get started with VS reporting?

      The path to VS reporting typically involves:
       

      • Define scope & module

        Select entities/sites and decide on Basic vs Comprehensive based on stakeholder needs and capacity.

      • Assess and select topics

        Use a pragmatic materiality lens to select relevant topics (e.g., energy, CO₂, workforce, supply chain, governance). Where a double materiality assessment has already been conducted, its findings can be drawn on directly to inform topic selection.

      • Identify gaps

        Identify gaps in data availability, processes, and responsibilities relative to the selected topics; align on priorities and timeline to close these gaps effectively.

      • Collect data & set processes

        Assign responsibilities, apply consistent methods, document sources and use templates/tools to gather ESG data.

      • Prepare the report

        Use the VS structure; avoid marketing language; explain assumptions and methods.

      • Publish & communicate

        Share with relevant stakeholders (e.g. customers, banks, partners) and ensure appropriate access;

        VS serves as a standardized response format.

      • Improve continuously

        Track KPIs, refine policies and controls, and adjust as needed; expand to the Comprehensive Module as maturity grows.

         

      Update “Voluntary Standard”

      In May 2026, the European Commission published a draft of its “Sustainability Reporting Standards for Voluntary Use” (VS) alongside the revised ESRS.

      The VS build directly on the VSME Standard developed by EFRAG, extending its reporting logic beyond SMEs and positioning it as a common reference framework for voluntary sustainability reporting outside the CSRD scope.

      The introduction of the VS is closely linked to the “value chain cap” under the revised CSRD. This mechanism limits the ESG information that in-scope companies may request from smaller, non‑in‑scope entities.

      While application remains voluntary, the delegated act establishes a legal framework for these limits, positioning the VS as the reference point for value chain-related data requests.

      Compared to the VSME, the VS introduce targeted refinements, in particular alignment with the simplified ESRS and a clear categorisation of datapoints (“necessary”, “if applicable”, “voluntary”), with only “necessary” datapoints falling under the value chain cap. Additional simplifications apply for micro‑entities.

      At the same time, the core VSME structure remains unchanged, including the two‑module setup and overall reporting logic.

      The draft VS is subject to a four‑week consultation and expected to be finalised as a delegated act thereafter.

      See: Sustainability reporting standard for voluntary use

      How KPMG Switzerland can support

      KPMG takes a pragmatic, outcome‑focused approach tailored to SMEs, combining ESG technical expertise with reporting and assurance know‑how.

      We guide clients through every stage of the process – from kick-off workshops and topic selection to gap assessments, VS data collection, report drafting, review, and optional limited assurance.

      Throughout, we draw on best-practice examples and provide targeted training to build lasting internal capability.

      Discover our services

      Ready to get started?

      Contact the KPMG Switzerland Corporate Sustainability Services team to discuss a right‑sized path to your first VS report and how to build from there.

      Contact our experts

      FAQ on VS

      The VS is a voluntary sustainability reporting framework for companies outside the scope of the CSRD. It aligns with ESRS logic but is simplified, proportionate and designed for cost‑effective ESG reporting.

      The VS is relevant for SMEs and other companies that are not subject to CSRD but receive sustainability information requests from customers, banks, investors or other stakeholders.

      Applying the VS is voluntary. However, the standard serves as the reference framework for sustainability information requests covered by the CSRD value chain cap..

      The VS is based on EFRAG’s VSME and remains largely aligned with it. Compared to the VSME, the VS includes limited modifications and reflects the European Commission’s final delegated regulation.

      The VS follows the structure and core principles of the revised ESRS but is significantly simplified.

      It contains fewer disclosures and is designed to be proportionate for smaller businesses..

      The VS legally establishes the sustainability information that companies reporting under the CSRD may request from businesses outside the CSRD scope under the value chain cap.

      The VS consists of a Basic Module covering core ESG disclosures and a Comprehensive Module for additional information on topics such as strategy, climate, workforce and governance..

      Companies typically begin by defining their reporting scope, assessing available ESG information, collecting relevant data and preparing disclosures aligned with the VS requirements.

      The VS does not require a formal double materiality assessment as defined under the CSRD, although companies should consider which sustainability topics are relevant to their business and stakeholders.

      VS reports are generally updated annually, based on fiscal year sustainability and ESG data, in line with financial reporting cycles.

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      Our capabilities

      • Sustainability reporting & VS advisory

        Support with VS scoping, module selection, gap assessments and report preparation, ensuring proportionate, high‑quality and decision‑useful sustainability disclosures

      • ESG data, controls & reporting processes

        Design and implementation of pragmatic ESG data collection processes, controls and documentation tailored to SME structures and available resources.

      • Independent assurance

        Independent reviews and optional limited assurance over sustainability information and VS reports, enhancing credibility with banks and business partners.

         

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