VSME: DRSC submits comment letter to the BMJV

On 11 February 2026, the German Accounting Standards Committee (DRSC) submitted a comment letter to the Federal Ministry of Justice and Consumer Protection (BMJV) concerning the European Commission’s recommendation for a standard on voluntary sustainability reporting for small and medium-sized enterprises (VSME). This submission followed a request from the BMJV on 3 February 2026, made in the context of a stakeholder consultation.

The background to this request is that the European Commission asked Member States to provide feedback on whether the future voluntary standard should be identical to the existing Commission recommendation (VSME) or deviate from it. The new, voluntarily applicable standard is particularly significant, as it will serve as a benchmark for limiting information requests along the value chain introduced by the Omnibus I Directive (the so-called Value Chain Cap).

In its comment letter, the DRSC notes that the standard, in the version recommended by the European Commission, has the potential to reduce individual information requests to SMEs, even though full harmonization seems unattainable due to the differing information needs of various stakeholders.

The comment letter is based on the DRSC’s extensive work on the VSME, including translation efforts in cooperation with the Austrian standard setter AFRAC, as well as preliminary results from exchanges conducted by the DRSC to assess the suitability of the VSME from the perspective of various stakeholder groups.

Considering the objective of retaining the VSME as far as possible in its current — potentially already applicable — version, the DRSC organises its feedback into three areas, which are detailed in the appendices to the comment letter:

1. Required corrections, for example identified during DRSC’s translation work;
2. Minor clarifications and amendments, arising from exchanges with various stakeholders; and
3. Aspects potentially requiring more extensive changes, which should therefore be discussed during the periodic review of the VSME (at least every four years).

In addition to the ongoing involvement of Member States, the European Commission also plans a short public consultation phase, expected to last one month in April/May 2026.