I don't have figures from last year, what do I fill in on the sustainability list
No baseline year? Fill in what you do have, and state that it's an estimate
The shortest answer: in the first year you usually fill in what you currently know, and indicate that it's an estimate rather than a measured value. EFRAG's VSME basic module is specifically designed for SMEs that do not yet have a multi-year measurement series — no historical series is imposed as a hard requirement. What matters is that the figure for the current fiscal year is available, with a clear note on how it was determined: an estimate based on energy invoices, a calculation using a standard emission factor, or information provided by a supplier.
For figures you don't have — such as scope 3 emissions from previous years — "not yet available, will be measured from this year onwards" is a valid answer, provided you genuinely intend to do so. Do not fill in an estimate as a measured figure: that creates an expectation your file cannot support, and the next questionnaire often asks for those same figures again. Do not confuse this, however, with business data that your customer asks for anyway, such as the number of employees of the undertaking or annual turnover — which are part of the basic identification and are separate from the sustainability figures.
What this is based on: the VSME basic module and the CSRD
EFRAG's VSME basic module was developed as an entry-level standard for non-listed SMEs that are not themselves subject to the reporting obligation of Directive (EU) 2022/2464 (CSRD), but do provide data to customers that are. This approach takes into account companies reporting for the first time: the basic module requests current data for the ongoing fiscal year, with room for an explanation of the method used, rather than a mandatory comparison with previous years. A customer who is themselves required to report under the CSRD must work towards measurable figures over time in their own supply chain — which is why they ask this year, even if there is no history yet.
What this is based on
- Trade Register Act 2007 — the data recorded for each company
- EFRAG VSME — the voluntary standard for non-listed SMEs, basic module
- Directive (EU) 2022/2464 (CSRD)
- ISO/IEC 27001 — Annex A, the control measures
- Directive (EU) 2022/2555 (NIS2), Article 21(2) — the ten measures
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.