The European Green Deal aims to achieve carbon neutrality by 2050. According to the European Parliament, this neutrality corresponds to a balance between greenhouse gas emissions and their absorption by carbon sinks, such as oceans, forests, and soils.
The Context
Within this framework for reducing greenhouse gas emissions, the European Union has implemented several instruments aimed at strengthening the consideration of sustainability issues by companies. Among them, the Corporate Sustainability Reporting Directive (CSRD) now requires certain companies to prepare annual non-financial reporting. In this perspective, companies are thus led to integrate sustainability issues more broadly into their strategy and operations.
The integration of environmental, social, and governance (ESG) criteria constitutes a major strategic lever for companies. Far from being a constraint, it represents a genuine driver for those seeking to improve their performance from a sustainable perspective. As an operational optimization tool, it particularly promotes the reduction of energy consumption, better waste management, and improved working conditions. These actions translate into concrete efficiency gains, with a direct impact on the company’s profitability.
What Is a Carbon Footprint?
In a company, the carbon footprint corresponds to an indicator that measures all greenhouse gas emissions generated by its activities, whether direct or indirect.
Direct emissions come from sources owned or controlled by the company, such as equipment or facilities used in the course of its business (for example, the combustion of gas fueling a bakery’s ovens).
Conversely, indirect emissions result from activities related to the company but beyond its direct control, such as those generated by its suppliers within its supply chain. The carbon footprint thus makes it possible to assess the organization’s overall climate impact.
Furthermore, the Greenhouse Gas Protocol, developed by the World Resources Institute, an international organization promoting sustainable development, defines emissions related to a company’s activity in three scopes.
Scope 1
These are emissions directly produced by the company’s equipment, facilities, and vehicles.
Scope 2
This corresponds to indirect emissions resulting from the production of energy consumed or purchased by the company.
Scope 3
This scope includes indirect emissions generated outside the company’s control perimeter but related to its activity: purchases, freight transport, travel, waste management, product use and end-of-life…
The Legislative Context
The European Union has adopted the Corporate Sustainability Reporting Directive (CSRD), whose main objective is to contribute to the transition toward a sustainable economy by strengthening the integration of environmental and social issues into corporate strategy. Part of the European Green Deal framework, this directive contributes to the carbon neutrality objective by 2050, particularly by improving corporate transparency regarding their sustainability actions.
It responds to the desire to establish a harmonized regulatory framework at the European level, ensuring more reliable and comparable communication of sustainability information. To this end, the CSRD relies on the European Sustainability Reporting Standards (ESRS), which structure reporting obligations around the three ESG pillars (environment, social, and governance) and specify the information companies must publish.
By requiring the publication of detailed non-financial data, particularly on strategies to address environmental risks, greenhouse gas emission reduction targets, and the contribution of activities to the ecological transition, the CSRD marks a turning point by transforming corporate social responsibility (CSR), historically voluntary, into a largely mandatory framework.
However, while this mechanism aims to strengthen transparency and encourage more sustainable practices, its implementation proves complex, particularly for intermediate-sized companies. It is in this context that the European Commission has initiated work to adjust the existing framework. We summarize the CSRD measures for you in our previous article.
The Omnibus I Directive
The entry into force of the European Omnibus I Directive on March 18, 2026, marks a significant shift in the deployment of the regulatory framework resulting from the Corporate Sustainability Reporting Directive (CSRD). This text is part of a simplification approach led by the European Commission, aimed at reducing the administrative burden on companies while preserving transparency objectives regarding sustainability.
The Omnibus I Directive thus reorganizes the implementation timeline, notably postponing the obligations applicable to companies in waves 2 and 3. Furthermore, it substantially simplifies reporting requirements by significantly reducing the volume of data to be published under ESG criteria.
One of the major developments lies in the raising of applicability thresholds. Henceforth, only companies simultaneously exceeding 1,000 employees and €450 million in annual net turnover are subject to CSRD obligations, compared to 250 employees and €50 million previously. This raising of the scope leads to the exclusion of a significant portion of initially concerned companies, particularly listed SMEs, and results, according to estimates, in the exemption of approximately 80% of previously targeted entities.
However, this apparent relief must be qualified. In practice, companies excluded from the direct scope of the CSRD remain exposed to increasing ESG requirements, particularly through their integration into value chains led by subject groups.
In this regard, Omnibus I introduces a value chain protection clause, aimed at regulating information requests addressed to companies with fewer than 1,000 employees. These requests may not exceed the scope defined by the Voluntary Sustainability Reporting Standard for SMEs (VSME), designed as a simplified and proportionate standard for SMEs. Find our analysis of the Omnibus directive.
A Structuring Framework for SMEs: The VSME Standard
The Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME) is a European standard designed for SMEs not subject to the CSRD but wishing to comply with it nonetheless. It offers a harmonized framework for structuring the production of non-financial information and building sustainable development strategies adapted to the capabilities of small and medium-sized enterprises, enabling them to present their ESG actions in a reliable and valuable manner.
Divided into two modules (basic and comprehensive), the VSME constitutes a progressive, proportionate, and flexible framework, allowing companies to advance at their own pace in integrating CSR issues.
It should be noted that the VSME is intended to evolve: it constitutes a temporary framework, pending the publication by the European Commission of a delegated act in 2026 concerning Voluntary Standards (VS), which will complement the voluntary reporting mechanism offered to companies with fewer than 1,000 employees. Discover our analysis of the VSME standard.
Why Adopt the VSME Standard?
Adopting the VSME standard represents, for companies, a strategic choice with multiple benefits, both in terms of compliance with sustainability information requests from commercial partners themselves subject to the CSRD and in terms of promoting their own ESG practices.
Anticipating Market Expectations and Legislative Changes
Even though SMEs are not subject to the CSRD, they increasingly face growing demand for ESG information from their clients, business partners, and financial institutions. This development reflects a ripple effect of the European regulatory framework, in which the reporting obligations of large companies gradually spread throughout their entire value chain.
The VSME establishes itself as a structuring tool. It enables SMEs to respond in a coherent, standardized, and proportionate manner to the ESG requests they receive. By harmonizing the information communicated, the standard helps reduce the dispersion of requests from principals and limit the redundancies often observed in ESG questionnaires. This standardization thus facilitates the integration of SMEs into the value chains of companies subject to the CSRD, enabling them to present their sustainability practices in a reliable, readable, and valuable manner.
The Omnibus revision also suggests a possible expansion of the scope of sustainability reporting in the coming years. While certain measures aim to reduce administrative constraints, they do not call into question the underlying dynamic of extending ESG requirements throughout the European economy.
In this perspective, the VSME is not limited to a simple voluntary reporting tool. It constitutes an intermediate structuring step, enabling SMEs to anticipate future regulatory developments and prepare, without organizational disruption, for a possible strengthening of sustainability obligations. It is thus part of a logic of gradual progression in companies’ ESG maturity.
Competitive Advantage
Furthermore, adopting a voluntary framework such as the VSME can be analyzed as a competitive advantage. It strengthens the company’s credibility in its business relationships and facilitates its access to certain markets, particularly those of large groups subject to enhanced reporting obligations. Conversely, the absence of ESG structuring may, over time, constitute an obstacle to participation in tenders or supplier qualification processes.
Optimizing Costs
The VSME also constitutes a lever for operational efficiency and a long-term investment. It enables the rationalization of non-financial data collection and reduces costs related to managing multiple and heterogeneous frameworks. It also contributes to better control of operating costs, particularly in sensitive sectors such as energy, in a context marked by the volatility of fuel and gas prices as well as geopolitical tensions. For SMEs, which often have limited resources, this structuring represents a significant organizational gain.
Protection for SMEs
Suppliers of companies subject to the CSRD may be requested to submit a report compliant with the VSME framework, particularly in the context of Scope 3 reporting, which requires increased transparency throughout the supply chain. These companies will be required to communicate structured non-financial information around four areas:
- General Information
The company describes its activity and its initiatives or projects regarding sustainable development.
- Environmental Indicators
It measures its environmental impact and describes the actions implemented to reduce it.
- Social Indicators
It reports information on its workforce, working conditions, and respect for human rights.
- Governance Indicators
The company communicates on its ethics, legal compliance, and initiatives regarding diversity in its governing bodies.
SMEs will therefore need to communicate both quantitative data and qualitative and narrative information describing their strategy, policies, impacts, risks, and objectives regarding environmental, social, and governance matters.
However, the Omnibus directive introduces the Value Chain Cap principle to protect the companies concerned. This prohibits companies subject to the CSRD from requiring their suppliers with fewer than 1,000 employees to provide information beyond the scope provided by the VSME standard. This allows SMEs, which do not have the resources or organization of large groups, to avoid an excessive administrative burden and not be penalized compared to their non-European competitors.
Six Levers for Action Within Your Company
To move from strategy to action, companies can rely on six concrete levers enabling them to effectively structure and deploy their sustainability approach.
1. Measure
The first step consists of conducting your company’s carbon footprint assessment. To do this, you can rely on the official resources of ADEME, particularly the GHG Assessment for Companies – ADEME Carbon Footprint mechanism, which defines the methodology for measuring all direct and indirect emissions produced by your activities.
By precisely defining your scopes 1, 2, and 3, you can assess the extent of your emissions, identify your priority emission sources (energy, purchases, transport, waste…), and prepare a structured and effective action plan to reduce your impact.
2. Reduce
The second step consists of reducing energy consumption by rethinking usage patterns and adjusting your business model. This involves limiting non-essential consumption, adopting an energy sobriety approach, improving energy efficiency, and working on optimizing energy performance. Implementing quick wins such as adjusting settings, automatic lighting shutoff, reducing travel, or internal awareness-raising enables rapid results without requiring significant investments.
3. Invest
The third step consists of investing in more efficient buildings and equipment. This involves modernization, insulation, improving facility efficiency, as well as optimizing energy consumption through more efficient equipment.
These investments can also be part of a transition toward greener energy sources, enabling sustainable reduction of emissions and operating costs.
4. Optimize
The next step is to optimize all resource usage by reducing waste and questioning needs related to heating, lighting, equipment, or travel frequency. Optimization also involves reflection around the eco-design of products and services.
In the transport sector, companies can define a mobility plan to optimize their fleet’s routes or rounds, or even use digital tools or AI to rationalize circuits.
5. Finance
To support these actions, it is possible to mobilize various financing mechanisms and subsidies. ADEME’s Ecological Transition for Companies platform enables identification of assistance adapted to one’s profile as well as relevant actions to undertake. Among the main available assistance are:
- Energy Savings Certificates (CEE), which finance energy performance improvement projects
- DECARB FLASH, which supports industrial activity decarbonization projects
These mechanisms enable significant reduction of the financial burden for companies wishing to undertake an ecological transition approach.
6. Train
Finally, it is essential to train teams on sustainable development issues and applicable standards, such as ESRS. This skills development contributes to creating a committed corporate culture, driven by managers and nourished by daily best practices.
Training also enables the construction of a credible transition strategy by defining quantified objectives and multi-year plans consistent with the company’s environmental ambitions.
In conclusion
With the relaxation of the CSRD framework, the VSME standard is progressively establishing itself as a voluntary reference standard, destined to sustainably structure ESG requirements within value chains. The minimum reporting baseline now expected of companies already constitutes the foundations of a future harmonized framework, likely to be enshrined by the European Commission and particularly relevant for SMEs and previously exempted companies.
In this context, mastering the carbon footprint becomes an essential strategic issue. It enables SMEs to anticipate regulatory developments, meet the growing requirements of principals, and strengthen their competitiveness in markets increasingly sensitive to sustainability criteria.
At NG, our certified sustainability experts support companies in structuring and implementing their CSR approach, in order to transform these obligations into genuine levers for performance, resilience, and sustainable growth. Contact us!