Missing Data and Estimates Under the EU Voluntary Standard: What Is Allowed?

A practical guide to estimates, unavailable information, not-applicable conditions, voluntary non-selection, permitted omission, improvement plans and internal review.

An SME rarely begins with perfect sustainability data. Utility bills may follow calendar months rather than the financial year, a landlord may not provide a renewable-energy split, one subsidiary may not record training hours consistently, and emissions often require conversion factors rather than direct measurement. The technical question is not simply whether a cell is blank. It is what the selected Standard requires for that exact paragraph or subpoint, whether the information can be estimated faithfully, and what the resulting status means for the B1 compliance statement.

The Standard contains several different datapoint categories: essential datapoints, information required only in specified circumstances, voluntary datapoints, sector-specific considerations and items that are voluntary for undertakings with 10 employees or fewer. It also permits omission of narrowly defined protected information under paragraph 22. These categories create legitimate reasons why information may not be reported. General operational unavailability is not itself one of those categories.

Figure 1. The status assigned to a difficult datapoint changes the disclosure, evidence and compliance consequence.

Greenhouse-gas emissions are expressly estimated

B3 paragraph 33 requires the undertaking - unless the datapoint is voluntary because it has 10 employees or fewer - to disclose its estimated absolute gross Scope 1 and location-based Scope 2 greenhouse-gas emissions. This wording recognises that emissions are ordinarily calculated from activity data, emission factors and assumptions rather than measured directly at the point of release. The estimate must still meet the quality characteristics in paragraph 11: relevant, faithful, comparable, understandable and verifiable.

Some breakdowns are required only when necessary information can be obtained

B3 paragraph 32 distinguishes total energy consumption from its detailed breakdown. For undertakings with more than 10 employees, total energy consumption in MWh is an essential datapoint. The renewable/non-renewable and electricity/fuels breakdown is required only if the undertaking can obtain the necessary information. If supplier or landlord information genuinely cannot be obtained, the conditional breakdown can remain unreported while the total is still reported. The evidence register should show the information request, the result and the paragraph-level conclusion; the total cannot be left blank merely because the breakdown is difficult.

EFRAG practical guidance contains estimation examples - but use the correct edition

Article 2(2) of the delegated act permits undertakings applying the Voluntary Standard to use practical guidance provided by EFRAG. The practical guidance currently available at the source cut-off was prepared for the 2025 VSME Recommendation and includes examples such as estimating water withdrawal from building bills, occupancy and fixture data, and estimating hours worked when calculating an accident rate. These examples are useful evidence that proportionate estimation can be an accepted implementation technique. However, the guidance predates the final 2026 text and must be checked for compatibility with the current paragraph, definition and selected option before it is treated as authoritative for a 2026 report.

Authority and purpose. Identify the disclosure, why estimation is appropriate and any official methodology or practical guidance used.

Boundary. Define the entities, sites, activities, workforce population and reporting period represented by the estimate.

Inputs. Record the primary and secondary data used, including extraction dates, units and source quality.

Method. Retain the formula, model, allocation key, emission factor or proxy and its version.

Assumptions and uncertainty. Explain significant assumptions, missing populations, sensitivity and known bias.

Review. Recalculate, compare with prior periods or financial records, challenge outliers and approve the residual uncertainty.

Disclosure and improvement. Describe the method and limitations proportionately and set a plan to improve the data where this would matter to users.

The word unavailable is useful in an internal gap register, but it is not a general reason for leaving an essential and applicable datapoint out of a report that claims compliance with a selected module. B1 requires the undertaking to select Option A or Option B and make an explicit compliance statement. A module must be complied with in its entirety, subject to the if-applicable principle and the Standard’s other stated categories.

Before publication, the undertaking therefore needs to decide whether it can resolve the gap, use a supportable estimate, document a genuine not-applicable condition, rely on an explicit voluntary category, apply paragraph 22, or change the reporting option and claim. For example, an undertaking that cannot complete the Comprehensive Module should not claim Option B. It may select Option A once the Basic Module is complete and, under paragraph 25, add selected Comprehensive disclosures without describing the report as a complete Option B report. The same solution is not available for an unresolved essential Basic datapoint.

Confirm scope. Is the paragraph or subpoint part of Option A, Option B, a selected additional disclosure or a separate customer request?

Identify category. Is it essential, conditional, explicitly voluntary, sector-specific or voluntary for an undertaking with 10 employees or fewer?

Test applicability. Does the exact condition in the disclosure apply to the undertaking’s facts?

Test estimation. Can a method produce information that is faithful and verifiable, and is the method consistent with the disclosure and current guidance?

Test paragraph 22. Does the information meet one of the protected-information grounds, and can the required B1 identification and annual reassessment be made?

Assess the claim. If the item remains unavailable, what does that mean for the selected module and any compliance wording?

Remediate. Record owner, action, resources, target date, interim control and approval decision.

Figure 2. Test scope, conditions, estimation and paragraph 22 before treating a missing datapoint as anything other than a gap.

Context. Northbridge Components is a hypothetical manufacturer with 68 employees and three sites. It intends to publish an Option A report. Electricity and fuel records are available, but the December electricity bill for one site is late, the landlord cannot provide a renewable-energy split, and one subsidiary has incomplete training records.

Decision. The reporting team estimates the late electricity consumption using the prior month adjusted for production hours and replaces it with the invoice in the post-close review. It uses the estimated energy input in the B3 GHG calculation and discloses the method and scale of the estimate. It reports total energy but not the conditional renewable/non-renewable split, retaining evidence that the necessary landlord information was requested and not obtained.

Training-hours gap. B10(d) is an essential Basic datapoint for this undertaking. The team cannot classify the missing subsidiary records as not applicable. Management delays the final compliance statement, reconstructs records from payroll, course invoices and attendance sheets, and introduces a central learning register. If it had remained unable to produce a faithful and verifiable figure, it would have needed to publish without an Option A compliance claim or defer publication rather than misclassify the gap.

Evidence retained. Utility source files, estimation working paper, factor table, landlord request, boundary reconciliation, training reconstruction, reviewer comments, management approval and the final dataset version.

A credible improvement plan is more than a promise to “collect better data next year”. It should address the root cause and create a testable control. The plan is an internal governance record and, where the gap is material to users, its main elements may also be explained in the output.

The Voluntary Standard is proportionate, but proportionate does not mean that every missing value can be waved away. A defensible reporting process makes the status of each datapoint explicit. Estimates are controlled reported information; not-applicable conclusions arise from stated conditions; voluntary non-selection arises from the architecture of the Standard; paragraph 22 omissions protect defined information; and genuine unavailability remains a gap. The organisation protects its credibility by documenting the difference, disclosing material limitations and aligning the B1 claim with what was actually completed.