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B1 – Basis for preparation

🗂️ VSME Basic Module – General information, page 8

  1. The undertaking shall disclose:

(a) which of the following options it has selected:

i. OPTION A: Basic Module (only); or

ii. OPTION B: Basic Module and Comprehensive Module;

(b) if the undertaking has omitted a disclosure as it is deemed classified or sensitive information (see paragraph 19), the undertaking shall indicate the disclosure that has omitted.

(c) whether the sustainability report has been prepared on an individual basis (i.e. the report is limited to the undertaking’s information only) or on a consolidated basis (i.e. the report includes information about the undertaking and its subsidiaries);

(d) in case of a consolidated sustainability report, the list of the subsidiaries, including their registered address [4] , covered in the report; and

(e) the following information:

i. the undertaking’s legal form;

ii. NACE sector classification code(s);

iii. size of the balance sheet (in Euro);

iv. turnover (in Euro);

v. number of employees in headcount or full-time equivalents;

vi. country of primary operations and location of significant asset(s); and

vii. geolocation of sites owned, leased or managed.

  1. If the undertaking has obtained any sustainability-related certification or label, it shall provide a brief description of those (including, where relevant, the issuers of the certification or label, date and rating score).

🗂️ VSME Basic Module Guidance – General information, page 15-16

  1. When reporting on the legal form of the undertaking according to national legislation under paragraph 24(e)(i), the undertaking can choose from one of the following undertaking structures:

(a) private limited liability undertaking

(b) sole proprietorship

(c) partnership

(d) cooperative

(e) other (please specify based on country specifications for legal forms).

  1. When reporting on the NACE code(s) of the undertaking under paragraph 24(e)(ii), NACE codes (Nomenclature statistique des Activités économiques dans la Communauté Européenne) are classifications of economic activities used in the European Union. They provide a standardized framework for classifying economic activities into sectors, enabling comparability and a common understanding among the various EU countries.

  2. The NACE code consists of a number of digits ranging from 2 to 5 depending on the level of specificity with which the economic activity is identified. The list of NACE codes can be found in the following document: REGULATION (EC) No 1893/2006.

Level Nr Identifier Description
1 Section Sections are identified by an alphabetic letter, and they define 21 general economic areas such as agriculture, manufacturing industry or commerce.
2 Division The division is identified by a two-digit numerical code and identifies a specific sector within the general economic area. There are a total of 88 divisions.
3 Group The group is identified by a three-digit numerical code (also considering the division’s two digits) and defines a specific area within the sector. There are about 270 groups.
4 Class The class is identified by a four-digit numerical code (considering the digits of division and group) and defines a specific activity within the group. There are about 450 classes.
  1. When reporting the number of employees under paragraph 24(e)(v), full-time equivalent (FTE) is the number of full-time positions in an undertaking. It can be calculated by dividing an employee’s scheduled hours (total effective hours worked in a week) by the employer’s hours for a full-time workweek (total hours performed by full-time employees). For example, an employee who works 25 hours every week for a company where the full-time week is 40 hours represents a 0,625 FTE (i.e. 25/ 40 hours).

  2. Headcount is the total number of people employed by the undertaking at a given time.

  3. When reporting on the country of primary operations and the location of significant assets under paragraphs 24(e)(vi) and (vii), the undertaking shall disclose this information for each of its sites using the table below:

Sites Address Postal Code City Country Coordinates (geolocation)
Registered Office (e.g.)
Warehouse (e.g.)
Industrial Plant (e.g.)
  1. The geolocation of an undertaking is expected to be a valuable datapoint for stakeholders for the assessment of risks and opportunities connected to the SME, particularly in relation to the sustainability issues of climate change adaptation, water, ecosystems and biodiversity.

  2. The geolocation shall be provided in spatial points for single units or polygon points defining the boundaries of a larger, less unit-like site, such as a farm, mine or facility. The undertaking may also provide a cluster of points to allow for the easy identification of the concerned area. The spatial points shall be provided as coordinates, with five decimal places (e.g. 0° 00′ 0.036″).

  3. When disclosing the geolocation of sites owned, leased, or managed, the undertaking shall include the coordinates of the sites in the table shown in paragraph 73. The undertaking may use web mapping tools (e.g. google maps, apple maps) to identify the coordinates of sites that it owns, leases or manages. The undertaking may also use any appropriate software tools or platforms to further establish the perimeter or area of larger sites.

  4. In relation to paragraph 25, sustainability-related certification can include registered eco-labels from an EU, national or international labelling scheme, corresponding to the main activity of an SME. For instance, the EU Ecolabel covers specific products, such as textiles and footwear, coverings (e.g. wood floor coverings), cleaning and personal care products, electronic equipment, or furniture. The undertaking may consult the EU Ecolabel Product Groups and Product Catalogue for further information.


[4] The registered address is the official address of the undertaking.