A useful timeline helps you identify which text you are applying. The practical risk for an SME is mixing a consultation draft, a recommended standard and an adopted act that is not yet effective.
From VSME to the Voluntary Standard
- December 2024: EFRAG delivers the final VSME, with Basic and Comprehensive modules.
- 30 July 2025: the Commission adopts Recommendation (EU) 2025/1710. VSME remains voluntary.
- December 2025: Italy's Sustainable Finance Roundtable publishes the SME–Bank/VSME interoperability table.
- February 2026: Directive (EU) 2026/470 changes the CSRD framework. The February 2025 Omnibus proposal and the final legislation must not be treated as identical.
- 11 June 2026: EFRAG releases Digital Template v1.3.0.
- 3 July 2026: the Commission adopts the new Voluntary Standard (VS) for undertakings protected by the value chain cap.
Sources: Commission CSRD acts, SME–Bank table.
Status checked on 14 September 2026
Additional milestone references: EU Council, February 2026 Omnibus, EFRAG, VSME delivery.
The Commission's official page still states that the 3 July act does not enter into force before publication in the Official Journal. Adoption, entry into force and application are different stages. Elapsed time alone does not establish legal effect.
The adopted VS addresses undertakings with an average of no more than 1,000 employees during the preceding financial year. This does not redefine an EU SME as any undertaking below that threshold.
EFRAG schedules its VS-aligned digital tools for Q4 2026. The currently available v1.3.0 template still relates to the VSME in the 2025 Recommendation. EFRAG source.
What to do with an existing dossier
Record the reference text and version, reporting period, organisational boundary, chosen module and software/template version. Keep a list of changes requiring reconciliation before the next update.
Preserve source data. Relabelling a report from VSME to VS is not a migration: some datapoints change content or move between disclosures.
2027 does not make VSME mandatory
Changes to CSRD and sustainability assurance do not, by themselves, create a general assurance obligation for voluntary SME reports. Any assurance engagement has a separate scope and conditions from report preparation.
Start with module selection and the data inventory.
This guide explains the documentary framework; it does not replace an assessment of the requirements applicable to an individual undertaking.