VSME/VS for accounting firms: a new engagement or a tempting idea that doesn’t pay off?

The question comes up in almost every firm: should we take up VSME/VS, or let it pass? Torn between the fear of extra workload and the sense that it could drive growth, firms are right to hesitate. The short answer: for an accounting firm, supporting a client on VSME/VS is a natural, structured and marketable engagement, provided it is scoped like any other engagement. Here is why, and how to dispel the most common objection along the way.

A natural engagement, not a regulatory fad

Let us set the scene. VSME/VS (Voluntary reporting standard for SMEs) is a voluntary sustainability reporting standard, developed by EFRAG and submitted to the European Commission on 17 December 2024, then endorsed by Commission Recommendation (EU) 2025/1710 of 30 July 2025, a non-binding soft law instrument. It is aimed at unlisted SMEs and micro-enterprises outside the mandatory scope of the CSRD. For a detailed look at its structure, see our pillar page on the VSME/VS standard and the voluntary standard.

And the context works in firms’ favour. Since the Omnibus I directive – Directive (EU) 2026/470 of 24 February 2026 – the scope of the CSRD has been limited to companies exceeding two cumulative thresholds: more than 1,000 employees and more than €450 million in net turnover. Many companies previously in scope are therefore leaving mandatory reporting. At the same time, their contracting customers keep sending them ESG questionnaires. This pincer movement – fewer legal obligations, just as many commercial requests – is precisely what swells the population needing a clear voluntary framework. And a firm already knows this population: they are its clients.

The decisive advantage: the data is already in the client’s accounting records

This is the point that non-accounting competitors cannot claim. A large share of the information required by VSME/VS is already sitting in the firm’s working papers or in the documents it handles every year.

• Energy and emissions (disclosure B3): energy invoices, already collected for the accounts, provide the basic consumption figures.
• Workforce (disclosures B8 to B10): employee characteristics, health and safety, remuneration and training can be read from payroll and social security filings.
• Resources and fixed assets (disclosure B7): tracking of fixed assets and purchases sheds light on resource use, the circular economy and waste management.
• Governance and ethics (disclosure B11): convictions and fines for corruption relate to checks that the firm already documents.

The VSME/VS Basic Module comprises eleven disclosures, from B1 to B11; the Comprehensive Module adds nine more, from C1 to C9, for those who wish to go further. Where an SME on its own would start from a blank page, the firm starts from a file that is already half complete. The engagement is not about inventing data, but about gathering it, structuring it and linking it to its evidence – a skill at the very heart of the profession. Our guide to applying VSME/VS step by step sets out this data → source → evidence logic.

‘The firm cannot provide assurance’: the myth to correct

This is the objection that stalls the most projects. It rests on a confusion. A VSME/VS report is voluntary: there is no statutory audit requirement for this type of document, unlike what the CSRD imposes on large companies. From this absence of obligation, many wrongly conclude that the firm has no role to play in lending credibility.

The reality is the opposite. Precisely because no audit is required, the door remains open to a service the client chooses. A chartered accountant – or a statutory auditor – can offer to go beyond simply producing the report and provide a form of third-party credibility: a voluntary assurance or review engagement, for example under a framework such as ISAE 3000, or an attestation for contractual purposes. The exact terms of these engagements remain to be confirmed in light of the positions of the profession (CNCC, the French institute of statutory auditors; H2A, the French audit regulator) and must be worded with caution. But the principle is clear: the absence of a mandatory audit prohibits nothing; it turns credibility into a selling point. For the client, a report that its accounting firm has looked over carries more weight with a bank or a contracting customer.

An engagement scoped like any other

What remains is to organise it as a proper service, not as an ad hoc favour. The profession’s standard practices are enough:

• An engagement letter defining the scope (Basic Module only, or Basic + Comprehensive Module), the work to be performed and the respective responsibilities.
• Working papers linking each published disclosure to its supporting document, with the usual supervision.
• Tiered production: staff accountant for collection, engagement manager for review, chartered accountant for supervision – exactly as on an accounting engagement.
• An optional credibility-enhancing service offered separately, when the client has a use for it.

VSME/VS requires neither double materiality nor an exhaustive analysis: it applies an ‘if applicable’ principle, which makes it workable for an SME. It is a bounded framework, which is precisely what makes it easier to roll out across multiple client files. The pillar page VSME/VS, a new engagement for accounting firms covers scoping, risk management and multi-client organisation.

So, a new engagement or more trouble than it’s worth?

On 8 November 2026, the state of the law supports the opportunity without overstating it: the voluntary standard (‘VS’), adopted by the Commission on 3 July 2026 and published in the Official Journal of the EU on 21 September 2026 (Delegated Regulation (EU) 2026/1560), has been in force since 24 September 2026 and takes over from the recommendation that endorsed VSME; it remains voluntary. In other words, the framework is stabilising, and the demand is already there.

For a firm, VSME/VS is not more trouble than it’s worth. It is an engagement that builds on data the firm already holds, meets a growing client need and comes with an optional means of enhancing the report’s credibility. The real mistake would be to treat it as a free service buried in the fixed fee, rather than as a service in its own right. To go further, see how a VSME/VS report can support a financing application.

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.