VSME Module Basic: A Disclosure-by-Disclosure Walkthrough
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This is the checklist post. If you want the strategic overview of why VSME exists and how Basic compares to Comprehensive, start with our VSME reporting guide. If you need help with the emissions calculation specifically, see our carbon accounting guide. This post walks through every Basic disclosure, in order.
How this walkthrough is structured
For each disclosure area, we cover:
- What to report — the specific data points
- Where to find it — the system, document, or person that has the data
- Good enough — what an acceptable first-cycle answer looks like
VSME Basic is designed so that most SMEs can complete it from existing records. If you find yourself building new data infrastructure for Basic, you are probably overengineering it.
B1 — General company information
What to report
- Legal name, legal form, registration number
- Sector codes (NACE or equivalent)
- Reporting period (typically your financial year)
- Total headcount at period end
- Locations (registered office + operational sites)
- Ownership structure (parent company, if applicable)
- Revenue and balance sheet total (to confirm SME status)
Where to find it
Your company register filing, annual accounts, and HR system. This is administrative data — nothing to calculate.
Good enough
Copy the exact data from your most recent annual accounts and company register extract. Do not round headcount — use the actual figure.
B2 — Energy
What to report
- Total energy consumption in MWh (or kWh, converted)
- Split by: purchased electricity, natural gas, heating oil, diesel, petrol, renewables, other
- Per site if you operate multiple locations
Where to find it
Utility invoices (electricity, gas), fuel card statements (vehicles), and heating oil delivery receipts. Your energy supplier’s online portal usually has annual summaries.
Good enough
Actual invoiced figures for the reporting period. If your reporting period does not align perfectly with billing cycles, pro-rate the last invoice. Do not estimate from costs — use the kWh or m³ figures directly.
B3 — Greenhouse gas emissions
What to report
- Scope 1 emissions (tCO₂e) — direct emissions from fuel combustion, company vehicles, refrigerant leaks
- Scope 2 emissions (tCO₂e) — indirect emissions from purchased electricity, location-based method
- Total Scope 1 + 2
Where to find it
Calculated from your B2 energy data using emission factors. See our carbon accounting guide for the step-by-step calculation, factor sources, and common mistakes.
Good enough
Actuals from invoiced energy data multiplied by recognised emission factors (DEFRA or EEA). No third-party verification required. Document which factors you used and their source year.
B4 — Pollution and water
What to report
- Pollutant emissions to air, water, or soil (if material)
- Water withdrawal by source (if material)
- Water discharge (if material)
Where to find it
Environmental permits, emissions monitoring reports, water utility invoices.
Good enough
If your sector is not water- or pollution-intensive (e.g., professional services, software, light retail): state that these disclosures are not material to your operations and briefly explain why. This is an acceptable answer — Basic does not require disclosure of immaterial topics.
If your sector is water- or pollution-intensive (e.g., food production, chemicals, textiles, metals): report actual monitored data from your environmental compliance records. If you hold an environmental permit, the data is already being collected.
B5 — Workforce
What to report
- Total employees at period end
- Breakdown by gender (male, female, other/not disclosed)
- Breakdown by employment type (permanent, temporary)
- Breakdown by working pattern (full-time, part-time)
- Number of non-employee workers (contractors, agency workers) if significant
- Health and safety: number of recordable work-related injuries, number of fatalities
Where to find it
HR system or payroll records for headcount breakdowns. Health and safety incident register for injury data. If you do not have a formal register, your insurer or occupational health provider may have the records.
Good enough
Exact figures from your HR system at the reporting period end date. For health and safety, report actual recorded incidents. If you had zero incidents, report zero — that is a positive data point, not a gap.
B6 — Governance and policies
What to report
- Existence of an anti-corruption or anti-bribery policy (yes/no)
- Existence of a human rights policy or commitment (yes/no)
- Existence of an environmental policy (yes/no)
- Whether employees receive training on these policies
- Existence of a whistleblower or grievance mechanism
Where to find it
Internal policy documents, employee handbook, company website. Many SMEs have these policies embedded in their employment contracts or code of conduct without realising they count.
Good enough
Yes/no for each policy. If you have a policy, provide a reference (internal document name or URL). If you do not have a formal standalone policy but the principle is covered in your employment contract or code of conduct, that counts — note where it is found.
Pulling it all together
The full Basic report is six sections. For most SMEs, the breakdown of effort looks like this:
| Section | Typical effort | Data source |
|---|---|---|
| B1 General info | 2–4 hours | Annual accounts, company register |
| B2 Energy | 4–8 hours | Utility invoices, fuel cards |
| B3 Emissions | 2–4 hours | Calculated from B2 |
| B4 Pollution/water | 1–2 hours | Environmental permits or materiality note |
| B5 Workforce | 4–8 hours | HR system, H&S register |
| B6 Governance | 2–4 hours | Policy documents |
Total: 15–30 hours of data collection, plus drafting and review time.
What comes after Basic
Once Basic is complete and shared with your counterparties, three things typically happen:
- Most customers accept it without further questions
- Some ask for one or two additional data points (usually Scope 3 or targets) — note these for your next cycle
- You have a baseline to improve on annually
If enough counterparties ask for more, that is when VSME Comprehensive enters the picture — along with double materiality and Scope 3 as specific topics.
Frequently asked questions
How many disclosures are in VSME Module Basic?
VSME Module Basic contains disclosures across five areas: general company information, environment (energy and emissions), pollution and water (if material), workforce, and governance policies. The exact number of data points depends on how you count sub-items, but a typical SME completes 25–35 individual data fields.
Do I need to report on every disclosure in VSME Basic?
Almost. General information, energy, emissions, and workforce disclosures are expected from all companies. Pollution and water are reported only if material to your sector — a consulting firm can skip water withdrawal, a food manufacturer cannot.
Can I leave a disclosure blank if I do not have the data?
You can note that data is not yet available and explain why. This is better than omitting the disclosure entirely. Banks and customers will accept a 'data not available — planned for next cycle' note in year one but expect the gap closed by year two.
How long does it take to complete all VSME Basic disclosures?
Most SMEs complete their first VSME Basic report in 40–120 hours of internal effort, spread across four to eight weeks. The time goes to data collection (60%), drafting (25%), and internal review (15%). Subsequent cycles are significantly faster because the data flows are already established.