CSRD and VSME 2026: sustainability reporting guide for French SMEs and mid-caps#
CSRD and VSME serve different legal purposes, but they answer the same management question: how can a company produce reliable ESG information without creating an administrative machine it cannot maintain? In 2026, the Omnibus simplification changes the CSRD scope and timetable, while VSME becomes the most practical voluntary framework for non-listed SMEs receiving ESG questionnaires from customers, banks, investors and large groups.
This guide complements our French articles on CSRD preparation, VSME 2026, ESG reporting, double materiality and carbon reporting. For support, see our ESG and CSRD service, statutory audit service, outsourced CFO service, CSR sector page and Power BI finance tool.
Executive summary#
CSRD is a mandatory sustainability reporting framework for companies in scope. VSME is a voluntary standard developed by EFRAG for non-listed SMEs that need a structured response to ESG data requests. The first 2026 step is therefore not drafting a report. It is qualifying the company's exact situation.
| Company situation | Recommended response |
|---|---|
| Large company or group in CSRD scope | Threshold review, timetable, ESRS workplan, governance and assurance readiness |
| Non-listed SME supplying a large group | VSME baseline, carbon data, social data and purchasing evidence |
| Startup or SaaS company raising funds | Investor-oriented VSME file, ESG KPIs and internal controls |
| Mid-cap close to thresholds | CSRD mapping, auditable data and consolidation process |
| Smaller company with no external demand | Selective voluntary reporting useful for banks and tenders |
Freshness note: updated on 3 May 2026. CSRD thresholds should be monitored as the Omnibus directive is transposed into French law.
CSRD vs VSME: obligation and usefulness are not the same#
CSRD is a publication obligation for companies falling within its scope. The French Ministry of Economy notes that CSRD strengthens environmental, social and governance publication requirements. The Omnibus directive adopted in late 2025 is expected to raise scope thresholds and reduce the number of directly affected companies after transposition.
VSME is not a mandatory mini-CSRD. It is a voluntary standard for non-listed SMEs, designed to make ESG data requests more consistent. It helps avoid ten different questionnaires using ten different definitions for energy, headcount, governance or carbon data.
Our accountant's view#
The main risk is not writing too few pages. The main risk is producing numbers that cannot be reconciled: HR headcount that differs from payroll, energy data without source documents, carbon estimates without method, governance claims without evidence, or supplier data that cannot be challenged. Sustainability reporting is becoming an internal-control discipline.
Which thresholds should be reviewed in 2026?#
Before building a reporting project, management must determine whether the company is directly in scope, indirectly requested, or only commercially exposed. Groups should review consolidated figures and foreign subsidiaries.
| Criterion | What to check |
|---|---|
| Employees | CSRD thresholds and Omnibus effects after transposition |
| Net turnover | EU and group threshold analysis |
| Balance-sheet total | Large-company or mid-cap qualification |
| Listed status | Listed SMEs are not treated like non-listed SMEs |
| International group | EU revenue, branches, subsidiaries and group reporting |
| Customer pressure | Scope 3 questionnaires, responsible purchasing and tenders |
Double materiality is useful even outside CSRD#
Double materiality looks at two angles: how the company affects people and the environment, and how ESG matters affect the company's financial performance. Even without a full mandatory report, a proportional version helps management decide what matters.
An e-commerce business may focus on transport, packaging, returns and warehouse energy. A software or consulting company may focus on recruitment, training, cybersecurity, responsible AI and customer concentration. A real-estate business will look at energy performance, refurbishment plans, asset value and transition risk.
VSME: the practical SME baseline#
EFRAG presents VSME as a voluntary standard for non-listed SMEs intended to answer data requests, support access to finance and improve sustainability management. For management teams, its value is repeatability.
| Data block | Evidence to prepare |
|---|---|
| Business model | Activities, sites, headcount and value chain |
| Environment | Energy, GHG emissions, water, waste and transport |
| Social | Workforce, accidents, training, equality and turnover |
| Governance | Purchasing policy, ethics, controls and responsibilities |
| Finance | ESG risks, capital expenditure, insurance and financing impacts |
The underestimated risk: last-minute customer questionnaires#
Many SMEs discover sustainability reporting through a tender. A key customer asks for emissions, anti-corruption policies, social indicators, a transition plan or purchasing data. If the answer is improvised, sales, HR, finance and operations may all submit different numbers.
Hayot Expertise's practical recommendation is to maintain an annual ESG data matrix with the data owner, source, date, method and supporting document for each figure. The matrix can live in a controlled spreadsheet, a reporting tool or a finance dashboard such as Power BI.
What management must decide#
| Decision | Why it matters |
|---|---|
| Use CSRD, VSME or internal reporting | Avoids a project that is too heavy or too weak |
| Appoint an ESG data owner | Clarifies customer and bank responses |
| Launch a carbon footprint or not | Structures the climate and Scope 3 section |
| Define update frequency | Makes data reusable for tenders |
| Prepare auditability | Helps if an auditor, customer or investor challenges the figures |
2026 watch points#
- Follow the French transposition of the Omnibus directive before communicating definitive CSRD obligations.
- Do not present a simple CSR questionnaire as CSRD compliance.
- Keep ESG data consistent with accounting, payroll and purchasing records.
- Document carbon assumptions, especially for significant indirect emissions.
- Expect banks and investors to trigger sustainability reporting before the law does.
Questions frequentes
Is a non-listed SME required to publish a CSRD report in 2026?+
Usually no. Non-listed SMEs are mostly affected by value-chain requests. However, group membership, listing status, thresholds and French transposition must be checked.
Is VSME enough for every customer request?+
It gives a strong baseline, but some customers will ask for sector-specific or more detailed carbon data. VSME should be treated as a reusable foundation, not a universal guarantee.
Should a company perform double materiality if it is outside CSRD?+
Yes, in a proportionate way. A short assessment helps avoid decorative KPIs and focus on data that clients, banks and investors will actually use.
Who should own sustainability reporting?+
Finance is often best placed to secure data quality, but HR, purchasing, operations and management must contribute. ESG reporting is not only a CSR function.
Does VSME require external assurance?+
Mandatory assurance concerns companies in CSRD scope. Under voluntary VSME reporting, the priority is to keep data traceable and credible if a customer, bank or investor reviews it.
Official sources used#
- French Ministry of Economy: CSRD and Omnibus update.
- EFRAG: VSME standard and SME sustainability reporting.
- European Union: CSRD directive and ESRS standards.
Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
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