VSME and SME suppliers: what your client
will ask you in 2026.

What VSME changes for SME suppliers

Before the Omnibus, the situation was unclear. Large companies subject to the CSRD sent carbon questionnaires to their suppliers with no standardized framework. Each client had its own format, its own requirements, its own deadlines. An SME supplying three large corporate clients could receive three different questionnaires, with incompatible scopes.

The VSME standard (Voluntary Sustainability Reporting Standard for non-listed SMEs), published by EFRAG in December 2024, changes the game. Since the adoption of the Omnibus, companies subject to the CSRD can no longer require their suppliers to provide data beyond the VSME framework. This is the “value chain cap,” a legal ceiling that protects SMEs against disproportionate requests, while standardizing what can be asked.

The European Commission must formally adopt the VSME through a delegated act by July 19, 2026 at the latest. But 67% of banks and large companies are already using it as the reference framework for collecting information from their suppliers (source: EFRAG, 2025).

The three VSME modules: which one applies to you

The VSME standard is structured into three progressive modules. As an SME supplier, you will likely only be concerned with the first two.

The basic module covers the essential indicators: energy consumption, CO₂ emissions (Scopes 1 and 2), workforce characteristics, health and safety at work, and governance. This is the minimum baseline, around 40 to 50 data points. For an SME with 30 to 100 employees, this is the most relevant module as a first step.

The narrative module lets you describe your strategy and governance around climate risks. It is recommended but not essential for a first report. If your client is only asking for your carbon data, the basic module is enough.

The “business partners” module is designed specifically to respond to client and investor questionnaires. It is the one most directly relevant to the supplier-client relationship. It adds around 40 additional data points, bringing the total to 85-90 indicators.

In practice, what data to prepare

Your large corporate client will ask you for at least the following data. The good news: most of it comes directly from your accounting records.

Energy and emissions (the core of the request): total energy consumption in kWh (electricity, gas, and fuel oil bills), breakdown by source (renewable vs. fossil), Scope 1 CO₂ emissions (direct combustion: company vehicles, gas heating) and Scope 2 (purchased electricity). For Scope 3, which represents 70 to 90% of an industrial SME’s emissions, the data is found in your accounting purchases: accounts 601 to 607 (raw materials), 624 (transport), 625 (travel), 612-613 (rentals).

Social: headcount by contract type, gender breakdown, workplace accident rate, training hours. This data comes from your HR department or your simplified social report.

Governance: existence of an anti-corruption policy, any convictions. For most SMEs, this is a simple declaration.

How to extract carbon data from your accounting records

This is the part most guides overlook. Your accounting records already contain the data needed to calculate your Scope 3 emissions — you just need to know how to read them.

The principle is simple: each class 6 accounting entry (expenses) corresponds to a type of spend. Each type of spend has an emission factor in the ADEME Base Carbone, expressed in kgCO₂ per euro spent (monetary ratio) or in kgCO₂ per physical unit (kWh, km, tonne).

For example, your raw material purchases (accounts 601-602) multiplied by the ADEME monetary ratio for your NAF sector give you your GHG Protocol Category 1 emissions. Your travel expenses (account 625) multiplied by the corresponding ADEME ratio give you your Category 6 emissions.

Oakbon automates exactly this process. You import your accounting export (FEC, Pennylane, Sage, or CSV), and Oakbon automatically maps each entry to the corresponding ADEME factors, following the French general chart of accounts. The result: a Scope 3 report aligned with the GHG Protocol and ESRS, ready to use to answer your client’s VSME questionnaire.

Timeline: when to act

July 2026: the European Commission adopts the VSME delegated act. This is the regulatory deadline. In practice, your clients won’t wait for this date to send you their questionnaires.

Right now: if you haven’t yet received a carbon data request, prepare by gathering your accounting export for fiscal year 2025. If you’ve already received a request, you can respond to it today with Oakbon in under two hours.

The best time to start is not when the delegated act is published. It’s when your client sends you their questionnaire, and that moment can arrive at any time.

Key takeaway: VSME is not an additional burden, it’s a protection. It limits what your clients can ask of you and standardizes the response format. By preparing for it now, you turn a commercial obligation into a competitive advantage.

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Oakbon automates the calculation of your Scope 3 emissions from your accounting records. Report in under 2 hours.

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