đź“„ Mid caps Sustainability Reporting Standards
Sign in

Introduction to the #WAE Mid Cap Sustainability Reporting Standard

Why add another sustainability reporting standard ? 

Encouraged by the European Commission to adopt a voluntary simplified approach through the VSME framework, many companies with fewer than 1,000 employees were initially drawn to this seemingly easier path.

However, at #WeAreEurope, we are seeing a different reality: more and more companies — especially structured mid-cap firms with 250 to 1,000 employees — are now realizing that this framework is not suited to their actual needs.

Why ?

  • Too simplistic to reflect their complexity
  • VSME was originally designed for small and micro-enterprises with fewer than 250 employees. It does not account for the more sophisticated structures and operations of larger organizations.
  • Inadequate for their investors
  • Investors require transparent, structured, and comparable ESG data to assess and manage risk effectively.
  • Neither strategic nor tailored
  • By omitting double materiality, value chain analysis, stakeholder mapping, and the description of strategies and policies, the VSME framework misses the essentials.

As a result, these mid-caps firms now face a methodological deadlock: 

  • The “complete” CSRD standard is intended for large companies, those in wave 1, and is currently being reworked.
  • VSME, which once appeared to be as an ideal solution has proven to be a dead end.

Mid-caps, once again, have been overlooked. No dedicated standard has been developed for them, and in the meantime, uncertainty prevails while deadlines are fast approaching. 

It is precisely to fill this gap that we have launched a collaborative initiative within #WeAreEurope. It's goal: Our ambition is for it to become the benchmark for all European mid-caps and their stakeholders.

How does this reporting standard has been drafted ? 

A working group was formed with European professionals — including mid-cap companies, consulting firms, ESG platforms, investment funds, and others. This group worked from March to June to define a Sustainability Reporting Standard through a series of collaborative sessions.

The group also developed a set of application requirements to ensure that the standard would be as simple and intuitive as possible for its future users.

Starting in June, the standard entered a second phase of broader testing, open to all interested professionals within the #WeAreEurope network.

Their feedback is helping to refine and enhance the standard in preparation for its wider rollout in the near future.

What is the structure of this reporting standard ? 

By design, this standard aims to be more ambitious and comprehensive than VSME in terms of reporting, while remaining less dense than the new Set 1 of the ESRS.

At the start of the initiative, since the final version of ESRS Set 1 was not yet available, the working group chose to use VSME as a base, enriching it with key data points deemed essential for reporting that reflects the reality and challenges of mid-cap companies.

The starting point was a merging of VSME’s Basic and Comprehensive modules, with the structure redesigned to align more closely with the ESRS framework. Each chapter of this standard corresponds to one of the ten ESRS topical standards (e.g., Climate Change, Pollution, etc.), with the exception of “Workers in the Value Chain,” “Affected Communities,” and “Consumers and End-users,” which have been grouped into a single chapter called “External Stakeholders.” The reason: their disclosure structures are highly similar in the original ESRS.

For each chapter (e.g., Climate Change, Pollution, Own Workforce), the working group identified the essential data points needed for a reporting framework that is realistic yet meaningful for mid-caps, avoiding excessive requirements given their scale. The group took an interoperability approach, drawing from existing frameworks such as the draft ESRS, Ecovadis, investor questionnaires, GRI, and others, to extract relevant disclosures tailored to mid-cap needs.

Some of the key disclosure requirements reintroduced into this framework include:

  • Double materiality analysis as a compass to identify relevant reporting topics

  • Mapping of the value chain and stakeholders

  • The Policy, Action, and Targets structure for each topic

  • The inclusion of Entity- or Sector-Specific topics, ensuring flexibility and relevance

How does it compare with other sustainability reporting standards ? 

By design, this standard cover all datapoints from VSME. 

Comparison to other standards incoming


Access to the Sustainability Reporting Standard

The #WeAreEurope Sustainability Reporting Standards is available at the following link: https://kdrive.infomaniak.com/app/drive/1590422/redirect/491 (if you don't have access to the file yet, please send your mail address to Walid Houfaf-Khoufaf on the #WeAreEurope Discord and he will grant you access)

In this file you'll find in the first sheet the history of modification between different version of Standards. For ESG platforms, that have already integrated the standards, you can refer to this sheet in order to update it. 

The second sheet in the excel file is the latest version of the reporting standards. 

Please while reading and/or testing the standards, fill this form to give us feedback, so that we can improve the standard: https://www.weareeurope.group/survey/start/e5fcaf60-77a7-4a45-a517-941891436708

Access to the Application requirements of the Sustainability Reporting Standards

This standard also has application requirements in order to guide future undertakings on how to report the data required by the standard. This resource will be completed with examples, guidelines etc in the coming future, to have the most clear and straight forward information for future undertakings. 

The Application requirements are available at the following link: https://kdrive.infomaniak.com/app/drive/1590422/redirect/500

While reading and/or testing the Sustainability Reporting Standards, if a datapoint is not totally clear for you, you can refer to the corresponding application requirements to have guidelines and information.

Please while reading the Application requirements, if you find datapoints for which the application requirements is not enough or even absent when one would be needed, you can send us feedbacks by commenting the Application Requirements, so that we can adjust it and make it the more efficient possible.