VSME/VS and financing: what is in it for banks and investors?

For some years now, no financing application has been limited to the financial statements alone. Banks, investment funds and ESG analysts factor environmental, social and governance (ESG) criteria into their decisions, including for SMEs that are not subject to any sustainability reporting obligation. The question therefore arises naturally: can the VSME/VS standard, the voluntary reporting framework designed for small and medium-sized enterprises, serve as a structured response to funders’ requests?

On 8 November 2026, the honest answer is a nuanced one: the VSME/VS could become a useful common language, but no French bank currently requires it. Institutions rely first and foremost on their own questionnaires. This page sets out the real landscape of requests, then explains how a VSME/VS report can feed into a financing application, without overselling a framework that is still young.

Legal status — as of 8 November 2026. The VSME/VS is a standard developed by EFRAG (submitted to the Commission on 17 December 2024) and endorsed by Recommendation (EU) 2025/1710 of 30 July 2025, a non-binding soft law instrument. The voluntary standard (VS), adopted by the Commission through a delegated act (C(2026) 5011) on 3 July 2026, was published in the Official Journal of the EU on 21 September 2026 (Delegated Regulation (EU) 2026/1560) and has been in force since 24 September 2026; the Recommendation has had no legal effect since that date. None of these instruments creates a reporting obligation for SMEs or any financing requirement based on the VSME/VS.

Why funders are interested in SMEs’ ESG data

The interest of banks and investors in sustainability is not a passing trend: it stems from their own regulatory constraints. A credit institution must assess the long-term risks of its counterparties — a physical climate risk at a production site, exposure to a sector in transition, a labour dispute — because these risks ultimately weigh on the borrower’s solvency. Investors, for their part, are required to document the sustainability of their investments.

For an SME, this has very practical consequences: when applying for a loan, raising funds or renewing credit lines, the funder may ask for information on energy consumption, greenhouse gas emissions, headcount and anti-corruption policy. These are precisely the topics covered by the Basic Module of the VSME/VS, through disclosures B1 to B11. A company that has already structured this data then has a usable foundation, rather than starting from a blank page with every request.

It is also worth recalling the underlying shift in the regulatory scope. Since the Omnibus I Directive (Directive (EU) 2026/470 of 24 February 2026), the scope of the CSRD has been narrowed to companies exceeding two cumulative thresholds: more than 1,000 employees AND more than €450 million in net turnover, for financial years beginning on or after 1 January 2027. A great many companies are thus leaving mandatory reporting, while still receiving requests from their banks and customers. It is precisely this group that is turning to voluntary reporting such as the VSME/VS.

A possible cycle: from VSME reporting to the funder’s readingDiagram in three steps linked in a loop. Step 1: the company produces VSME reporting (Basic Module B1 to B11, Comprehensive Module C1 to C9). Step 2: this reporting could become part of the financing application. Step 3: the bank or investor could read it to inform its decision. Feedback can feed into the next reporting cycle. The wording is conditional: the VSME is a possible document, not a mandatory one. Badge: legal position as of 08/11/2026.The VSME in the financing applicationA possible, hypothetical cycle — the VSME remains voluntaryLEGAL POSITION AS OF08/11/2026STEP 1VSME reportingBasic B1–B11Comprehensive C1–C9 (opt.)Published ESG dataSTEP 2Part of the fileThe reporting could jointhe financing application,alongside financial statementsSTEP 3Read by the funderThe bank or investorcould use it toinform its decisionFeedback can inform the next cycleWhat the law says — and what it doesn’tThe VSME is a recommendation (EU Rec. of 30/07/2025): it remains voluntary for unlisted SMEs.No text requires it in a financing application: it is a possible use, left to the parties.CSRD scope: > 1,000 employees AND > €450m net turnover; VS delegated act adopted on 03/07/2026.
VSME/VS: a possible part of the financing application

What French banks actually ask for today

Let us stick to the facts: in 2026, there is no single ESG data collection standard imposed on SMEs by the French banking sector. Each group has developed its own questionnaire, often linked to its internal scoring tools. A company that banks with several institutions may therefore receive several different forms, with varying formats and scopes — which is precisely the fragmentation the VSME/VS seeks to reduce.

Behind these questionnaires, two bodies of regulation shape funders’ requests, without ever targeting the SME directly:

  • The SFDR (Sustainable Finance Disclosure Regulation): it requires financial market participants to disclose sustainability information on their products and to document the adverse impacts of their investments. To do so, they collect data from the companies they finance.
  • Prudential Pillar 3: banks must disclose information on their ESG risks, notably climate risks. This leads them to map the exposure of their loan portfolio, and therefore to request information from their counterparties.

The result is a very real demand, but an indirect and heterogeneous one. The SME is approached not because a rule applies to it, but because its funder must comply. Understanding this mechanism helps avoid over-interpreting the requests received: they do not create any legal reporting obligation for the company.

Current bank requests and the possible role of the VSMETwo-column comparison table. On the left, what banks actually ask for today: ESG questionnaires specific to each institution, SFDR indicators (principal adverse impacts) and Pillar 3 information on sustainable assets. On the right, the VSME as a possible standardised response: a single foundation built on the Basic Module (B1 to B11) and the Comprehensive Module (C1 to C9), reusable and comparable from one bank to another. A dated box recalls the legal position: Commission recommendation of 30 July 2025, delegated act adopted on 3 July 2026; the VSME remains voluntary for companies below the dual threshold of 1,000 employees and €450 million.What banks ask for — and the possible role of the VSMEFinancing pillar · ESG requirements vs a standardised reporting baseCurrent bank requestsThe VSME as a standardised responseIn-house ESG questionnairesEach institution sends its ownform: formats, scopes andindicators differ with each request.A single reusable baseThe Basic Module B1–B11 coversa common core: answer once,send to several banks.SFDR indicators (PAI)For their funds, banks requestthe principal adverse impacts:GHG, energy, pay gap…Alignable dataThe Comprehensive Module C1–C9provides the data points thatSFDR indicators can draw on.Pillar 3 reportingPrudential constraints: the bankmust disclose the “green” share of itsoutstanding loans (green asset ratio).Upstream comparabilityA common format for companiesfeeds these ratios without multiplyingcase-by-case restatements.The VSME remains a voluntary standard for companies below the dual threshold (fewer than 1,000 employeesand €450m turnover): it serves as a common language, not a new obligation for these SMEs.Legal position — as of 08/11/202630 July 2025 — European Commission recommendation encouraging use of the VSMEas a voluntary sustainability reporting standard for SMEs.3 July 2026 — delegated act adopted: it clarifies the interplay with data requests frombanks and large client companies. Regulation (EU) 2026/1560, OJEU of 21/09/2026.
Current bank requests and the possible role of the VSME/VS

The VSME/VS as a possible standardised response to these requests

This is where caution is required. The VSME/VS could act as a common response to requests that are currently scattered: rather than filling in five separate bank questionnaires, an SME could produce a single VSME/VS report and provide it, in whole or in part, to each lender or investor. The benefit would be threefold: a pooled data collection effort, consistency in the figures communicated, and greater credibility stemming from the use of a recognised European framework rather than an in-house format.

Two caveats are in order, however. First, to our knowledge, no French institution had replaced its proprietary questionnaire with the VSME/VS format on 8 November 2026: adoption is a reasonable bet, not an established fact. Second, a bank questionnaire may ask for items that go beyond the scope of the VSME/VS (forward-looking financial data, specific sector indicators); the report therefore does not always remove the need for additional information. The VSME/VS is a usable foundation, not a master key.

The right stance is therefore proactive but measured: build a solid VSME/VS report, use it as the basis for responses, and present the funder with a structured, sourced document where many companies have only piecemeal answers. To build this foundation, the method is set out in our guide applying the VSME/VS standard in SMEs and micro-enterprises.

The Commission’s recommendation: limiting requests to the scope of the VSME/VS

One point deserves the attention of business leaders and bankers alike. By endorsing the VSME/VS, the European Commission is pursuing an explicit objective: to make this framework the ceiling of what it is reasonable to ask of a small company. The guiding idea is that an SME should not be asked, in the name of sustainability, for more than the content of the VSME/VS.

This approach is given legal form through the mechanism known as the value chain cap, provided for by the Omnibus reform. It aims to limit the ESG information that large companies subject to the CSRD may require from their partners with 1,000 employees or fewer, by referring to the content of the voluntary standard. This mechanism does not directly concern the lending relationship, but it establishes a benchmark — “do not ask for more than the VSME/VS” — whose spirit may, over time, permeate funders’ practices. This mechanism, whose entry into application depends on the forthcoming transposition, is explained in detail on our page dedicated to the VSME/VS and the value chain.

For an SME receiving such requests, the argument is useful: having a VSME/VS report makes it possible not only to respond, but also to frame the request by relying on a scope recognised by the Commission as proportionate.

New on 3 July 2026. Recital 5 of the delegated act expressly invites financial institutions, financial market participants, insurers and credit institutions to limit as far as possible their information requests to companies with 1,000 employees or fewer to the content of the voluntary standard – including outside the context of sustainability reporting. This is not a prohibition, but it is an argument that can be invoked in discussions with a funder.

From VSME/VS report to financing application: a practical guide

In practice, how does VSME/VS reporting fit into a bank application or a fundraising round? Here is a pragmatic outline.

  1. Produce the report in advance, not in a rush. A financing application takes preparation; a VSME/VS report compiled in haste loses reliability. Planning ahead makes it possible to have figures that are consistent with the attached financial statements.
  2. Select the relevant information. Not all disclosures B1 to B11 are of equal interest to a funder. Energy and emissions data (climate-related information), headcount and anti-corruption governance are often the most closely scrutinised. The Comprehensive Module (disclosures C1 to C9), which notably adds emission reduction targets and a climate risk analysis, can strengthen an application to a demanding investor.
  3. Document traceability. A funder gives more credence to a data point linked to its source (energy bill, staff register, accounting records). The data → source → evidence approach, developed in the application guide, makes the data more robust.
  4. Attach the report as a supporting document, not as a marketing tool. The VSME/VS report is presented as a factual annex to the application, in the same way as the accounts. Its value lies in its restraint and verifiability, not in promotional rhetoric — non-financial credibility rests on measurement, not on communication.

On this last point, the support of an accounting professional makes all the difference. An accounting firm already holds a large share of the source data and can structure the report, or even provide a voluntary assurance engagement on it, which strengthens the funder’s confidence. We describe this approach on the page the VSME/VS, a new engagement for accounting firms.

Complementing carbon footprinting and ESG ratings

The VSME/VS does not replace the tools many SMEs already use; it links them together. Three complementarities are worth setting out:

  • With carbon footprinting. The climate disclosures of the VSME/VS are based on energy and emissions data that largely overlap with a greenhouse gas inventory. An SME that has already measured its carbon footprint has much of the data required; conversely, carbon is only one component of the VSME/VS, which also covers social and governance matters.
  • With ESG ratings (such as EcoVadis). These ratings are based on proprietary questionnaires and scoring scales; the VSME/VS, by contrast, is a standardised reporting framework. The two are not mutually exclusive: data structured through the VSME/VS can feed into a third-party assessment. The subject is addressed head-on in our comparison of frameworks.
  • With the financial application itself. From a funder’s point of view, the strength of VSME/VS reporting lies in its closeness to the accounts: the same documents often support both the financial and the non-financial figures. It is this continuity that distinguishes a reproducible report from mere CSR rhetoric.

In other words, the VSME/VS acts as a point of convergence: it provides a common framework for initiatives previously carried out in silos, and makes this information easier for a bank or investor to read.

FAQ

Can a bank require a VSME/VS report?

No. No rule requires a company to produce a VSME/VS report, and no French bank imposes it as a format to date. The VSME/VS is a voluntary framework: a bank may ask for ESG data, but it does so through its own questionnaire. Nothing prevents a company, however, from offering its VSME/VS report on its own initiative as a basis for its response — indeed, it is often an advantage.

Does the VSME/VS improve financing terms?

On 8 November 2026, there is no mechanism guaranteeing that a VSME/VS report will improve an interest rate or a credit decision. What the VSME/VS offers is more indirect: a better-documented application, consistent and traceable ESG data, and greater credibility with a funder that must itself report on the sustainability of its portfolio. It is a source of confidence, not a promise of preferential terms.

Should a VSME/VS report be certified for a bank?

No statutory audit is mandatory for a voluntary report. A demanding funder may, however, give greater weight to a report that has been subject to a voluntary assurance engagement (for example under ISAE 3000) carried out by a chartered accountant or a statutory auditor. It is not an obligation, but an additional source of credibility.

My SME is no longer within the scope of the CSRD: is the VSME/VS still of interest to my funders?

Yes, and its relevance is even greater. With the raising of the CSRD thresholds (more than 1,000 employees AND more than €450 million in net turnover), many companies are leaving mandatory reporting while still receiving requests from their banks and customers. The VSME/VS offers them a proportionate voluntary framework for responding to these requests without being drawn into the complexity of the ESRS.

Which VSME/VS data are of most interest to an investor?

Generally, climate data (energy and greenhouse gas emissions), headcount and governance indicators such as anti-corruption policy. A demanding investor will also value the elements of the Comprehensive Module (disclosures C1 to C9), in particular emission reduction targets and climate risk analysis, which reflect a trajectory rather than a mere snapshot.

To find out more, see our full overview of the VSME/VS standard, the guide to producing your report step by step, or follow developments in the regulatory framework in our VSME/VS and VS news watch.

Sources and verification — checked on 8 November 2026

Every regulatory statement on this page has been checked against the official text. The references below allow you to verify them for yourself.

  • Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026 (adopted under reference C(2026) 5011), “supplementing Directive 2013/34/EU of the European Parliament and of the Council by establishing sustainability reporting standards for voluntary use by undertakings protected by the value chain cap” — legal basis: Article 29ca(1) of Directive 2013/34/EU. Published in the Official Journal of the EU (L series) on 21 September 2026, in force since 24 September 2026 (Article 4); its Article 3 (value chain cap) applies to financial years beginning on or after 1 January 2027. Official text on EUR-Lex · version adopted on 3 July 2026 (PDF, European Commission). Relevant provisions: Articles 1 (definition of the cap), 2(1) (who may apply the standard), 3(2) (the cap covers only the data points in Annex II), 4 (entry into force), recital 5 (end of the legal effects of the Recommendation, message to lenders and investors). Transmitted to the European Parliament and the Council on 3 July 2026 (Council document 11697/26 of 9 July 2026).
  • Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 (adopted under reference C(2026) 5010, revision of the ESRS): reduces the number of mandatory data points by 61%. Published in the Official Journal of the EU on 21 September 2026; enters into force on 10 November 2026 (Article 3) and applies to financial years beginning on or after 1 January 2027. Official text on EUR-Lex · adopted version (PDF, European Commission).
  • Recommendation (EU) 2025/1710 of 30 July 2025 (endorsement of EFRAG’s VSME), OJEU of 5 August 2025 — text on EUR-Lex. Recital 5 of Delegated Regulation (EU) 2026/1560 provides that it “should be considered as no longer producing legal effects” from the entry into force of that regulation, i.e. from 24 September 2026.
  • Directive (EU) 2026/470 of 24 February 2026 (Omnibus I), published in the OJEU on 26 February 2026, entered into force on 18 March 2026 — text on EUR-Lex. National transposition due by 19 March 2027 at the latest.
  • EFRAG — VSME/VS digital template and XBRL taxonomy, version 2.0.0 of 4 November 2026 (prepared in accordance with the voluntary standard (VS), Delegated Regulation (EU) 2026/1560 published in the Official Journal of the EU on 21 September 2026; it replaces version 1.3.0 of 11 June 2026, which EFRAG says should no longer be used) — EFRAG page.

A question about the timeline? We track the status of each text, with dates, in our regulatory watch.