How Much Effort Does the Voluntary Standard Involve in Practice – and How Can It Be Implemented Efficiently?

One of the first questions companies tend to ask about the Voluntary Standard: how much time and resource should realistically be planned for, and how can implementation be made as efficient and cost-effective as possible? There's no blanket answer. But there is a range of useful reference points that help put the effort into perspective.

Why the effort is likely to be lower than under ESRS

Compared with CSRD reporting under ESRS, the effort involved in the Voluntary Standard is likely to be more manageable for several reasons, though this can only be assessed credibly through concrete points, not blanket statements:

• A formal double materiality assessment isn't required. That removes one of the most time-intensive steps of ESRS reporting entirely.

• The Basic Module covers considerably fewer data points than ESRS, with the Comprehensive Module adding a manageable number of further ones. Both modules work with an essentially fixed, predefined catalogue. ESRS, even after being streamlined in the recent revision, covers a multiple of that number.

• The Basic Module only requires Scope 1 and Scope 2 greenhouse gas emissions. Scope 3 emissions across the up- and downstream value chain, among the most resource-intensive metrics of all, aren't mandatory there, and would at most feature, optionally, within the Comprehensive Module.

• The resulting report is likely to be considerably more compact than a full ESRS report, which can run to several hundred pages depending on the company. Even with the Comprehensive Module included, the Voluntary Standard remains in a different order of magnitude.

That shouldn't create the impression that everything is already covered

However much lower the effort compared with the CSRD, it would be misleading to suggest that the Voluntary Standard requires little more than assembling what's already there. Even within the standard, some disclosures involve real effort to determine. One example from the Basic Module is confirming whether employees receive at least an adequate wage. This requires comparison against relevant statutory or collectively agreed benchmarks and isn't always readily apparent from existing payroll data. Another is average training hours per employee, which isn't systematically tracked in every company. Where the Comprehensive Module is used and Scope 3 is included on an optional basis, one of the most methodologically demanding metrics in sustainability reporting is added on top. The real difference to CSRD lies less in the Voluntary Standard being free of complex disclosures altogether, and more in the fact that far fewer such disclosures are mandatory, with companies able to decide for themselves how deep to go.

Still worth some groundwork: a rough understanding of relevant topics

Even though the Voluntary Standard doesn't require a formal materiality assessment, it's likely worth developing at least a broad understanding of the sustainability topics relevant to the company, similar to what a simplified, top-down approach also allows under the revised ESRS. The reasoning: anyone later describing a policy or an action on a given topic should be able to explain what it's actually referring to. A vague, generic statement is unlikely to carry much weight.

This doesn't require an in-depth stakeholder survey, but typically some exchange with relevant internal teams to build a basic understanding of the company's situation. Depending on ambition and level of detail, even a simplified exercise like this could take a few weeks, depending on capacity, internal turnaround times, and the desired level of granularity.

A clarification on the "if applicable" principle

The Voluntary Standard's "if applicable" principle is sometimes confused with a materiality test. The difference matters: a disclosure isn't dropped simply because a topic is considered less significant from a business perspective. It only falls away where the underlying matter genuinely doesn't apply to the company. One example: even where water isn't a strategically central sustainability topic for a company, the relevant disclosure on water withdrawal in the Basic Module would generally still need to be made, provided the company withdraws water at all. That marks a clear distinction from the logic of a materiality assessment.

Stocktaking: often more available than expected

An initial review frequently shows that many of the required disclosures already exist somewhere within the company in some form. Typical examples likely to already be tracked include headcount, waste data, or the number of work-related accidents, information many companies document for other reasons anyway. In such cases, the effort tends to lie less in first-time data collection and more in pulling together data from different sources and departments into a consistent structure.

This doesn't apply equally to every disclosure. Some metrics, even within the Basic Module, are likely to require genuine collection effort, for instance Scope 1 and location-based Scope 2 emissions, which not every company already tracks systematically.

Qualitative disclosures on practices, policies or initiatives follow a different logic than quantitative metrics: if a company doesn't yet have a policy on a given topic, that's not a problem in itself. It simply reports that none exists. For quantitative metrics, the position differs: where a required disclosure hasn't previously been collected, that generally doesn't remove the obligation to determine and report it. The "if applicable" principle only applies where the underlying matter genuinely doesn't apply, not merely because the data hasn't been gathered yet.

Defining responsibilities and processes

Data collection typically involves several teams at once. Clearly defined responsibilities, who provides which disclosure, who consolidates the data, who updates it the following year, and who signs off on the finished report, are likely to be key to a smooth process. Without that structure, even a fundamentally manageable standard risks generating unnecessary coordination effort.

Implementing efficiently: clarify stakeholder needs upfront

For an efficient implementation, it's worth clarifying early on what information the relevant audience actually needs. For mid-sized companies, the Comprehensive Module is likely to become relevant on a regular basis, since the Basic Module alone often may not fully cover the information needs of banks or larger business partners.

One point to bear in mind: even where a company applies the Voluntary Standard in full, banks or major customers may still request disclosures beyond its scope, provided the request doesn't serve the requesting company's own CSRD reporting obligation, for example as part of an internal rating process. The Voluntary Standard provides a strong starting point here, but doesn't necessarily replace every individual request.

Tools as a genuinely useful aid, though not a requirement

Especially across multiple reporting years, a tool can provide a valuable foundation: it brings the relevant data together in one place, allows responsibilities to be assigned per data point, supports a fixed update frequency, and ensures data is aggregated on the same basis year after year. That tends to reduce manual coordination effort considerably once the process is set up. A number of straightforward tools are now available on the market that are built specifically for this purpose.

A dedicated tool isn't a prerequisite, though: where other systems are already in place that capture relevant data, a workable, repeatable process can often be built around those instead. What makes sense in a given case depends on the structures already in place within the company. Setting the process up for the first time requires a certain amount of lead time either way, regardless of whether a tool is used.

A closer look can still be worthwhile

Even though a double materiality assessment isn't required under the Voluntary Standard, taking a rough look at the company's own relevant topics can help build a more strategically coherent report and prepare the ground for a possible future transition to CSRD reporting. This isn't a prerequisite for applying the standard, but it can strengthen the report's substance.

In summary: a pragmatic, though not effort-free, starting point

Taken together, the Voluntary Standard is likely to offer a considerably more cost-effective and faster route into sustainability reporting than full ESRS reporting. That said, it isn't effort-free: a basic understanding of relevant topics, clear processes and defined responsibilities remain worthwhile even under a comparatively lean standard.

For a general introduction to the Voluntary Standard, see [What is the Voluntary Standard (formerly VSME)? A quick overview]; for a detailed comparison with ESRS reporting, see [Voluntary Standard (formerly VSME) vs. CSRD/ESRS: where are the differences?]. Anyone considering voluntary assurance can find more in [Voluntary assurance under the Voluntary Standard: when it might be worth it].