At the end of 2025, many French SME leaders heard a reassuring phrase, often summarised a little too quickly.
“The CSRD has been scaled back. You are probably out of scope.“
For some, it sounded like a return to normal. For others, like a new grey area. And that is precisely where the misunderstanding begins.
Because in reality, even when an SME is not directly required to publish sustainability reporting, it is increasingly often asked to respond. Not by the state. Not by a law arriving by registered mail. But by the market. A large client wanting to secure its supply chain. A bank gradually integrating extra-financial criteria into its risk analysis. An insurer wanting to understand exposure to climate risks. A buyer requiring information for a tender.
In other words, for many SMEs, the pressure does not disappear. It changes path.
That is exactly what the reform known as “Omnibus” reveals in depth — presented by the European Commission on 26 February 2025, then negotiated between the Commission, the European Parliament and the Council.
Let us start with the acronyms, because that is often where things get blurred.
CSRD is the European directive on corporate sustainability reporting. It replaced and expanded the former NFRD directive, which covered a more limited number of companies. The original CSRD idea was clear: move from “declarative” extra-financial reporting to reporting that is more structured, more comparable, more auditable, and above all covering many more companies. We were talking about a shift from roughly 11,000 companies to more than 50,000 across Europe.
To make this reporting comparable, the European Union also established ESRS, the European Sustainability Reporting Standards. These are the standards that describe precisely what to publish and how. They can be seen as a grammar. Without this grammar, each company tells its sustainability story in its own way. With it, you can compare, verify and analyse.
Then there is CSDDD, sometimes called CS3D, the directive on corporate sustainability due diligence. Here we are no longer talking only about publishing information, but about demonstrating a logic of managing and preventing risks and impacts across the value chain.
And finally there is the European Taxonomy, which aims to classify economic activities according to their environmental contribution, notably in finance.
Omnibus touches this whole set — not to say “everything stops“, but to say “we refocus, we sequence, we limit the direct scope“.
That is where the key point for an SME appears.
Political discussions around Omnibus led, at the end of 2025, to a clearer targeting logic focused on the largest companies. The EU Council explains, for example, that the compromise aims to concentrate reporting obligations on companies with more than 1,000 employees, with a net turnover threshold above €450 million in the agreement mentioned. The European Parliament also communicated along these lines after its vote on 16 December 2025 on the provisional agreement.
For many SME leaders, the instinctive reading is simple.
“So it is no longer for me.“
But this conclusion misses the real mechanism.
Because if the direct legal obligation narrows, the economic logic continues to expand. And it even accelerates, because large companies remain obliged, and their compliance depends on the quality of information they obtain from their suppliers — many of whom are SMEs.
This is where the notion of “trickle-down” becomes central. The law does not hit the SME directly, but it transforms expectations around it.
In 2026, this phenomenon will become more visible, more structured and more demanding, because major players will need information that is more stable, more comparable and less improvised.
And it is precisely to organise this trickle-down that VSME takes its full place.
VSME, the Voluntary Sustainability Reporting Standard for SMEs, is a voluntary standard designed for micro-enterprises and unlisted SMEs. It was developed by EFRAG, the body mandated to structure the European sustainability reporting architecture. In France, the RSE Portal, supported by the state, presents VSME as a voluntary framework providing a common language for responding to stakeholder expectations and structuring an approach.
The word “voluntary” is often misunderstood. Many hear it as “optional“. In an SME’s real life, voluntary mainly means “controlled“. It means not waiting to be caught by a client emergency to improvise. It means choosing to organise information upstream, at your own pace, with a proportionate framework.
And this framework did not fall from the sky. The European Commission itself published a formal recommendation, Recommendation (EU) 2025/1710 of 30 July 2025, to encourage use of this voluntary standard and facilitate its adoption by the market. In this recommendation, the idea is explicitly to reduce the multiplication of distinct information requests addressed to SMEs and to favour comparability at lower cost.
This point deserves to be stated simply, as you would to a leader.
VSME serves to transform the chaos of questionnaires into a stable response. Instead of filling ten different formats depending on clients, the SME creates a single, reusable reference base that becomes its foundation for discussion with the outside world.
So it is not “yet another report“. It is a management and credibility tool.
In France, this logic is already relayed by highly visible actors among leaders. Bpifrance, for example, published a briefing presenting VSME as a voluntary framework for structuring a CSR approach. And on the national obligations side, even if not all SMEs are concerned, there are also mechanisms such as BEGES, the Greenhouse Gas Emissions Assessment. The Ministry of the Economy reminds us that certain companies must produce a BEGES, notably above employee thresholds, and that this exercise fits into a logic of measurement and planning.
The ecosystem is structuring itself. Requests are becoming more technical, more verifiable, more comparable. And the more this structures, the more improvisation costs dearly.
That is where another source of confusion arises for SMEs: the difference between “saying” and “proving“.
In 2026, companies will not only be questioned about their commitments. They will be questioned about their ability to be consistent. Large companies will compare answers from one year to the next. Banks will detect inconsistencies in narratives. Rating platforms will align their questionnaires with more standardised frameworks. What you tell client A must remain compatible with what you tell client B. And it is this consistency that becomes the real issue.
It is also where initiatives such as “VSME Medals” appear in the ambient noise.
Let us be clear. VSME Medals are not an official European Union standard. They are not issued by EFRAG, the Commission or a French public body. But they reveal something important: the market is looking for simple, visible markers to measure an SME’s ESG maturity. The VSME Medals site presents a tiered recognition system designed to make a structured progression around the VSME framework readable.
In a leader’s real life, the interest of such a scheme, when properly understood, is not to “collect a badge“. It is to have a readable signal in a saturated universe, where clients demand quick proof and SMEs need a common language. It is also a way to transform an internal approach into a simple external message — provided visibility is never confused with substance.
What Omnibus reveals is not a retreat from sustainability. It is a maturing of the system. The regulator refocuses the direct scope on the very largest players. But the system continues to expand through economic relationships, because that is the only way to circulate information in a value-chain economy.
For a French SME, the 2026 question is therefore not “am I required to produce CSRD reporting?” The real question is much more operational.
When my client sends me an ESG questionnaire, am I able to respond without mobilising three people for two weeks? When my bank asks for a view on my risks, am I able to respond with coherent data? When I talk about my company, am I able to be consistent, credible and not contradict myself depending on the interlocutor?
VSME is becoming the framework that makes this consistency possible, without turning the SME into a large company, and without requiring bureaucracy the SME cannot sustain.
And if we must retain one thing from Omnibus, it is this.
Sustainability in Europe is entering a phase where structure matters more than legal scope. Companies that have minimal structure, clear responsibilities, a simple data logic and a stable way of responding will be those that experience the least pressure. Those that confuse “out of scope” with “outside the system” will be those that discover too late that the system has already integrated them.
SME support: find out how to structure your answers to ESG and VSME questionnaires.
