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.

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.

Webinar Mid-Caps SRS: What is the best ESG reporting framework for your company in 2026?  

How is the #WAE Mid-Caps Sustainability Reporting Standard structured ?

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 did we proceed to draft the #WeAreEurope mid caps reporting standard ?

A working group was formed with over 20 European professionals — including mid-cap companies, consulting firms, ESG platforms, investors, and ESG experts. 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.

After a phase of broader testing open to all professionals within the #WeAreEurope network and its adaptation to the latest ESRS, the final version of the Mid-Caps SRS is now available to all!