VSME/VS: a new engagement for accounting firms

Q: How can you persuade a client to launch a VSME/VS engagement?

By starting from their situation: most SMEs approach VSME/VS after a concrete request (an ESG questionnaire from a customer, a call for tenders, a request from their bank). The key argument is that the firm already holds most of the necessary data (energy, payroll, fixed assets, purchasing) and that a structured report avoids answering each request separately.

The VSME/VS standard (the sustainability reporting standard designed for unlisted SMEs and micro-enterprises outside the scope of the CSRD) is often presented as a topic for corporate social responsibility consultants. That reading is incomplete. In practice, the person who already knows an SME’s figures best, who handles its energy bills, payroll data, fixed assets and purchases every year, is its chartered accountant. The firm is therefore ideally placed to turn VSME/VS into a clear, recurring advisory engagement.

This page is aimed at chartered accountants, statutory auditors, their staff and the associations de gestion et de comptabilité (French approved accounting and management associations). It explains why VSME/VS is a natural extension of the profession, how to scope and deliver the engagement, and it corrects a persistent misconception: no, an accounting professional is not condemned to remain a bystander to a sustainability report. They can produce it, and even lend credibility to its output.

Why VSME/VS is a natural engagement for the firm

VSME/VS was developed by EFRAG and submitted to the European Commission on 17 December 2024, following the mandate given by the SME Relief Package of 12 September 2023. Its primary aim is to give small businesses a single, proportionate framework for responding to ESG requests from their customers, their banks and client companies, without having disparate questionnaires imposed on them. In other words, VSME/VS is a tool for simplification and standardisation, which is exactly where an accounting firm adds value.

Three reasons make this engagement a natural fit. First, positioning: the firm is already the SME’s trusted third party, the one entrusted with its figures. Second, method: producing a structured report from supporting documents, building working papers and tracing each data point back to its source is the core of accounting work. Finally, commercial timing: with the Omnibus reform, the scope of the CSRD is narrowing to only those companies that exceed two cumulative thresholds: more than 1,000 employees and more than EUR 450 million in net turnover (applying to financial years beginning on or after 1 January 2027). Many companies are therefore falling out of scope while continuing to receive ESG requests. This population, now turning to voluntary reporting, is a natural market for accounting firms.

The decisive advantage: most of the data is already in the accounting file

This is the central argument, and it deserves to be stated plainly. A significant share of the information required by the VSME/VS Basic Module (disclosures B1 to B11) is already present, in one form or another, in the SME’s file kept by the firm.

Most of the source data is already in the firm's hands

Take the most concrete disclosures. Disclosure B3, which covers energy and greenhouse gas emissions, draws directly on electricity, gas and fuel invoices, documents the firm already records. The social disclosures on workforce (B8), health and safety (B9), and remuneration, collective bargaining and training (B10) derive from payroll and social security filings, which the firm or the accounting and management association produces or supervises. Fixed assets, the vehicle fleet and the premises used appear on the balance sheet. Purchasing and the cost structure shed light on resource use and waste management (B7).

The firm therefore never starts from a blank page. Its added value lies not in collecting non-existent data, but in reorganising data that is already there according to the structure of VSME/VS, obtaining whatever is missing (a few physical indicators, a formalised policy) and ensuring the traceability of the whole. This repositioning changes everything in how the engagement is sold: it is not one more project, but a way of leveraging material the firm already holds.

One methodological caveat is necessary, however. EFRAG does not publish any official number of data points for VSME/VS: the totals in circulation come from third-party counts and vary according to the level of granularity used. It is therefore prudent to think in terms of disclosures B1 to B11 and C1 to C9, rather than quoting a figure as if it were official. For details of the content of each module, see the page VSME/VS standard: definition, modules and status.

Scoping the engagement: engagement letter, scope, procedures

Like any service, a VSME/VS engagement begins with written scoping. The engagement letter sets out the purpose (assistance in preparing a VSME/VS report), the module chosen (Basic only, or Basic plus Comprehensive), the scope of the entities and sites concerned, the reference financial year, the allocation of roles between the client and the firm, and the expected deliverables.

The choice of module shapes the effort. The Basic Module (B1 to B11) is the common foundation for any company applying VSME/VS. The Comprehensive Module (C1 to C9) is added when the client, or one of its stakeholders, needs more detailed information: strategy, climate targets, human rights, governance. This choice is made case by case, depending on the actual request that triggered the project. On the logic behind such requests (customer questionnaire, bank requirement, call for tenders), see VSME/VS and the value chain and VSME/VS and financing.

The procedures are then defined: which data will be extracted from the accounting file, which will require an interview or collection from the client, and what level of verification the firm applies. It is important to be clear about what the engagement is not: unless specifically agreed, an engagement to assist in preparing the report is not an assurance engagement. This essential distinction is discussed further below.

A structured engagement, from letter to deliverable

Producing and securing: working papers, supporting documents, supervision

The production phase draws on the profession’s established practices. Each disclosed item must be traceable to a source and to evidence: the energy figure to the invoice, the headcount to the social security filing, training to the training plan and the corresponding supporting documents. This data → source → evidence matrix forms the working papers and protects the client as much as the firm should questions arise later. The same logic is set out, from the SME’s perspective, in the guide Applying VSME/VS in SMEs and micro-enterprises.

VSME/VS is based on a principle of proportionality, sometimes summed up by the phrase ‘if applicable’: a company reports only what genuinely concerns it, and flags the indicators that are not relevant to its activity. The firm then makes sure these choices are documented, so that the absence of a data point is a reasoned and traceable decision, not an oversight.

As for tools, EFRAG’s official Excel template offers a free and structured starting point; its limitations become apparent mainly when producing reports across multiple client files. The full overview is covered in Tools and software for VSME/VS reporting. Finally, supervision follows the firm’s usual hierarchy, from staff member to signatory, which ensures a consistent level of quality from one file to the next.

Assurance and third-party credibility

This is where a persistent myth needs correcting. It is often said that ‘the firm cannot attest to’ a sustainability report. This claim confuses two things: the absence of an audit obligation, and the possibility of an assurance engagement. The two are not mutually exclusive.

Legal status — as of 8 November 2026

VSME/VS: standard developed by EFRAG (submitted on 17 December 2024), endorsed by Commission Recommendation (EU) 2025/1710 of 30 July 2025. It is a soft law instrument, non-binding, with no penalties or mandatory filing, and it ceased to produce legal effects on 24 September 2026 (recital 5 of Delegated Regulation (EU) 2026/1560).
VS (voluntary standard): adopted by the Commission by means of a delegated act on 3 July 2026 (reference C(2026) 5011), published in the Official Journal of the EU on 21 September 2026 (Delegated Regulation (EU) 2026/1560). It has been in force since 24 September 2026. VSME/VS and VS are two related but distinct instruments; it would be premature to speak of a mere change of name.

Updates are tracked in our regulatory watch.

No mandatory statutory audit of a voluntary report

VSME/VS is a voluntary framework. A report prepared under this framework is not subject to any statutory audit or third-party verification requirement. An SME can publish its report, or hand it to a customer, without any external review. This is a freedom, not a constraint.

Since 3 July 2026, this point is no longer a matter of interpretation: recital 5 of the delegated act provides that “undertakings applying the standard are not required to have the information they disclose verified”. The caveat regarding French practice (positions of the CNCC and H2A, the French statutory auditors’ institute and audit regulator) still stands: it is the European obligation that is ruled out, not the usefulness of voluntary assurance.

But a voluntary assurance or review engagement remains possible (ISAE 3000 type, subject to confirmation by the CNCC/H2A)

The absence of an obligation does not rule out the opposite approach. An accounting professional may offer, as an option and on request, a voluntary assurance or review engagement intended to strengthen the report’s credibility in the eyes of a bank, a contracting customer or an investor. Assurance engagements on information other than historical financial information fall, in practice, under frameworks such as ISAE 3000. It is precisely this third-party credibility that distinguishes a self-declared report from one whose consistency has been reviewed by a professional.

A word of caution: the exact regime applicable in France (nature of the engagement, who may perform it, under which framework and with what level of assurance, reasonable or limited) must be confirmed with the competent bodies (CNCC, H2A) before entering into any formal commitment. This page presents a market opportunity, not a fixed regulatory framework. Caution on this point protects the client as much as the firm.

Pricing the engagement: a method based on complexity, without a published fee scale

A VSME/VS engagement cannot be priced as a single fixed fee: the effort depends mainly on the complexity of the file. Rather than quoting a rate, it is better to reason in terms of workload drivers and build a tailored quote.

The module chosen: Basic only, or Basic plus Comprehensive, the latter requiring more qualitative and strategic information.
Data availability: a client whose payroll and general accounts are already kept by the firm will require far less data collection than a partially outsourced file.
The scope: a single entity, as opposed to a group with multiple sites or establishments.
The level of service: simple assistance with preparation, or an engagement including voluntary assurance, which adds procedures.
Recurrence: the first year bears the scoping and set-up effort; subsequent years, essentially an annual update, are priced considerably lower.

This driver-based reasoning makes it possible to justify a quote to the client and to explain objectively the difference between a small file and a complex one, without ever publishing a fee scale.

Organising and scaling up: who produces what, across multiple files

VSME/VS comes into its own when a firm handles it at scale rather than on a one-off basis. The allocation of roles then follows the firm’s usual organisation.

Who does what in a VSME/VS engagement

The staff member handles production: extracting data from the file, entering it into the template, assembling the supporting documents. The engagement manager carries out the review, checks consistency between data and evidence, and clears outstanding points. The chartered accountant supervises, decides on difficult methodological choices and signs off on the work. This chain, already well established for accounting engagements, applies seamlessly to VSME/VS.

To scale up, a few levers: standardise a reusable engagement letter and working papers template, build a library of sources by type of data, and build on each year’s work, since most of the file is updated rather than recreated. EFRAG’s Excel template is enough to get started; beyond a certain volume of files, a more fully featured solution becomes worthwhile, a trade-off discussed in Tools and software for VSME/VS reporting.

Frequently asked questions

Can the firm attest to a VSME/VS report?

No statutory audit is mandatory for a VSME/VS report, which falls under a voluntary framework. However, a professional may offer, on request, a voluntary assurance or review engagement (of the ISAE 3000 type) to lend the report credibility with a bank, a contracting customer or an investor. The precise regime applicable in France must be confirmed with the CNCC and the H2A (the French statutory auditors’ institute and audit regulator) before any commitment. The idea that ‘the firm cannot attest’ is therefore inaccurate: it may not be required to do so, yet it can offer to.

How can you persuade a client to launch a VSME/VS engagement?

By starting from their situation, not from the standard. Most SMEs approach VSME/VS because they have received a concrete request: an ESG questionnaire from a large customer, a requirement in a call for tenders, a request from their bank. The most effective argument is twofold: the firm already holds most of the necessary data (energy, payroll, fixed assets, purchasing), which limits the burden on the client; and a structured report, possibly backed by third-party assurance, avoids having to answer each request separately. To help a business owner find out whether it applies to them, point them to the definition of the VSME/VS standard and to the guide Applying VSME/VS in SMEs and micro-enterprises.

Do you need to be a statutory auditor to work on VSME/VS?

Not for assistance in preparing the report, which is part of a firm’s day-to-day engagements. The question of which professional is authorised arises specifically for an assurance engagement: its exact framework in France must be confirmed with the competent bodies. The value chain of ESG requests and the role of each stakeholder are detailed in VSME/VS and the value chain.