CSRD on a budget: sustainability reporting for companies that aren’t listed

The Omnibus package took most unlisted companies out of the CSRD. It did not take your biggest customer’s procurement team out of your inbox. Brussels stepped back; the banks and buyers who were always the real requesters stepped forward — now with a legal ceiling on what they can ask.

What the Omnibus actually did

The timeline, because the press coverage blurred it: the Commission proposed the first Sustainability Omnibus on 26 February 2025. A « stop-the-clock » directive followed in April 2025, deferring the later reporting waves. The Omnibus I directive hit the Official Journal on 26 February 2026, in force from 18 Mars 2026 (EY; PwC Ireland).

What changed for you:

• Scope shrank by roughly 80–85%. Mandatory CSRD reporting now requires both plus que 1,000 employees on average et net turnover above €450 million (Council/Commission final text, summarised by EY). Listed SMEs were removed from scope entirely. A 50-person company is nowhere near either threshold.
• A value-chain cap became law. Companies with up to 1,000 employees are « protected undertakings »: large CSRD reporters may not request sustainability information from them beyond what the EU’s voluntary standard contains — and protected undertakings may refuse requests that exceed it (PwC Ireland).
• The voluntary standard exists. The Commission endorsed EFRAG’s VSME standard via Recommendation (EU) 2025/1710 in July 2025, and adopted the Voluntary Standard via delegated act — Commission Delegated Regulation (EU) 2026/1560, in application since 24 Septembre 2026 (KPMG; Fiegenbaum). It is based on the VSME, keeps the two-module structure, and doubles as the value-chain cap.

Nobody will fine you for not reporting. Somebody will ask anyway — and you now have a defensible limit.

Who is really in scope

Not the regulator. Your counterparties. EFRAG’s cost-benefit analysis — a survey of more than 4,400 SMEs across 13 Member States — found nearly 43% of medium-sized enterprises already receive ESG data requests from buyers and lenders, a share expected to approach 100% by 2028 (EFRAG CBA, via Karomia). Banks fold the same data into loan pricing; two large customers means two questionnaires, and the answers rarely transfer.

The VSME is the answer-once format. Against full ESRS it is dramatically lighter (PwC comparison): roughly 96 data points instead of ~314, a basic module plus an optional comprehensive module instead of 12 standards, no mandatory double materiality assessment, and assurance optional rather than compulsory. Start with the basic module — energy, emissions, workforce, governance — which covers most of what buyers and banks ask. Add the comprehensive module (Scope 3 estimates, climate risks, targets) only when a lender or tender demands it; EFRAG puts the extra cost at roughly double.

What a first report costs a 50-person company

The published numbers, which are more useful than any vendor quote:

• EFRAG’s cost-benefit analysis (Syntesia/Prometeia, using the EU Standard Cost Model): a small/medium enterprise (20–250 employees) using the basic module faces first-year costs of about €7,500–12,800, mostly staff time, dropping to €3,500–6,000 per year thereafter. Basic plus comprehensive: €17,500–22,800 in year one, €8,500–11,000 recurring.
• Internal effort for a 20–100 person SME: 40–75 hours spread across finance, RH, operations and management — at a loaded internal rate of €50–80/hour, €2,000–6,000 of staff time (Verdeledger).
• Consultant day rates: €800–3,500 depending on seniority, with senior CSRD specialists at €1,200–2,500 in the DACH market (CSRD-Experts). A consultant-led first VSME basic-module report runs €5,000–10,000, falling to €2,500–5,000 in later years (EFRAG CBA via CSRD Pro; ESG for Suppliers).
• Software platforms: €300–3,500 per year depending on size (EFRAG CBA via CSRD Pro).
• Full ESRS, for contrast: a double materiality assessment alone lists at €10,000–25,000 for an SME, and full implementation at €25,000–75,000 (CSRD-Experts). That is the train you mostly no longer need to catch.

The honest budget line for a 50-person company doing VSME basic in-house with a light external QA pass: roughly €3,000–6,000 in year one, half that afterwards.

Five data sources you already have

The VSME basic module was designed around data that already exists. Before hiring anyone, collect twelve months of:

1. Utility bills. Électricité, gas and district-heating invoices for every site give you energy consumption and most of your Scope 1–2 carbon. 2. Print and copier logs. Meter readings and paper purchase orders cover resource use — and typically expose that three machines do 60% du volume. 3. Travel bookings and fuel cards. The booking tool export, matched to the vehicle list, is your transport emissions without a single new form. 4. Waste invoices. Waste contractors bill by stream — paper, packaging, mixed, hazardous. That is the VSME waste disclosure, already itemised. 5. Procurement ledger. Your purchase ledger, categorised, supports the spend-based Scope 3 estimate if you ever add the comprehensive module.

Assign one coordinator, align the period to your fiscal year, and write nothing until the basic-module data is in one folder.

Ce que tu sauves

Answer once, not four times: about €7,000 a year.

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A 50-person company fielding three ESG questionnaires a year spends 30–100 hours on them (Verdeledger); EFRAG’s survey work puts the fully-loaded cost of a single request at up to €7,100 (Karomia, citing the EFRAG CBA). At the conservative end — three requests, 30 hours, €80/hour — that is €7,200 a year of duplicated work a single VSME report replaces with « see our report. »

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Starting now, calmly, costs €7,500–12,800 once (EFRAG), then €3,500–6,000 a year. Scrambling in 2027 — when wave-one customers file their first CSRD statements and supplier data requests multiply, at rush rates from senior consultants billing €1,200–2,500 a day — means paying the questionnaire toll et the premium. One Belgian manufacturer that started early qualified for an ESG-linked loan 15 bps cheaper — about €3,000 a year. The €7,000 is the number that survives a hostile CFO.

Sources

• KPMG, VSME: A voluntary sustainability reporting option (Incl. Sept 2026 adoption update): https://kpmg.com/xx/en/our-insights/ifrg/2025/omnibus-vsme-standard.html
• PwC Ireland, Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME vs ESRS comparison): https://pwc.ie/services/audit-assurance/insights/vsme-voluntary-sustainability-reporting-standard-non-listed-smes.html
• EY, EU Sustainability Developments — Omnibus Content Directive in force (Mars 2026): https://www.ey.com/content/dam/ey-unified-site/ey-com/en-gl/technical/csrd-technical-resources/documents/ey-gl-eu-sustainability-developments-revised-delegated-act-on-eu-taxonomy-enters-into-force-03-2026.pdf
• Mayer Brown, European Commission Presents « Omnibus » Simplification Package (Feb 2025): https://mayerbrown.com/en/insights/publications/2025/02/european-commission-presents-omnibus-simplification-package-with-amendments-to-csrd-csddd-cbam-and-taxonomy
• EFRAG/Syntesia–Prometeia, Cost-Benefit Analysis on the VSME: https://efrag.org/system/files/sites/webpublishing/Project%20Documents/2309261112573240/EFRAG%27s%20Cover%20Letter%20and%20Cost%20Benefit%20Analysis%20on%20VSME.pdf
• Commission européenne, Impact assessment accompanying the revised ESRS delegated act (IMMC SWD(2026) 500): http://publications.europa.eu/resource/cellar/d108ba08-76c9-11f1-bf5e-01aa75ed71a1.0001.03/DOC_1
• CSRD Pro, What Does CSRD Reporting Cost for SMEs in 2026: https://csrdpro.com/en/csrd-reporting-cost-for-smes
• Verdeledger, Sustainability Reporting Cost and Timeline for SMEs: https://verdeledger.eu/blog/sustainability-reporting-cost-timeline-sme
• CSRD-Experts, CSRD Consultant Costs 2026 (day rates): https://csrd-experts.com/blog/csrd-consultant-costs
• ESG for Suppliers, ESG Consultant vs DIY (VSME report fees): https://esgforsuppliers.com/guides/esg-consultant-vs-diy-honest-comparison
• Karomia, Stop Drowning in ESG Requests (cost-per-request, loan-spread case): https://karomia.eu/blog/stop-drowning-in-esg-requests-one-vsme-report-can-do-it-all
• Fiegenbaum Solutions, VSME Sustainability Reporting: Basic vs Comprehensive Modules (VS application date, basic-module data list): https://fiegenbaum.solutions/en/blog/vsme-sustainability-reporting-basic-vs-comprehensive-modules

Prochaine fuite à réparer

The value-chain cap limits what buyers can ask — not what they will keep asking until you hand them something reusable. Build the answer bank this quarter: one folder, one fiscal year, five data sources, one VSME basic report. When the wave-one customer’s questionnaire lands in January, the right answer is a link, not a fortnight of someone’s life. The policy-and-reporting playbook lives at /category/policy-reporting/.

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Carla Lavigne is Green Ops Editor at mycompanyisgreen.org and the colleague who brings the calculator to the audit.