Short answer
The answer, before the reasoning
Option A means applying the Basic Module only; Option B means applying both the Basic and Comprehensive Modules. B1 requires the undertaking to identify the selected option and make an explicit statement of compliance using that option.
Each selected module is applied in its entirety, but that whole-module rule does not override the classifications inside the Standard: “if applicable” items are reported only when their circumstances apply, voluntary/may datapoints remain voluntary, specified datapoints are voluntary for undertakings with 10 employees or fewer, and a permitted paragraph 22 omission must be identified. Selected C disclosures can be added to an Option A report, but they should be presented as supplementary and must not be used to imply full Option B.
Option A or Option B decision tree: choose the claim after Basic completeness, user need and evidence are tested.
Technical status
LEGAL-STATUS NOTE
The European Commission adopted C(2026) 5011 on 3 July 2026. At the source-check date, the Commission status page stated that the delegated act was not in force until publication in the Official Journal. Recheck the final EU number, scrutiny outcome, entry into force and any changed wording immediately before publication.
In practice
The comparison in one table
| Decision point | Option A | Option B |
|---|---|---|
| Modules selected | Basic Module only. | Basic Module and Comprehensive Module. |
| Prerequisite | Complete B1-B11. | Complete B1-B11 before applying C1-C9. |
| B1 statement | Explicit Option A compliance statement. | Explicit Option B compliance statement. |
| Whole-module rule | Basic is applied in its entirety. | Both Basic and Comprehensive are applied in their entirety. |
| If-applicable items | Reported only when the stated circumstances apply. | Same rule in both modules. |
| Voluntary/may datapoints | Remain voluntary. | Remain voluntary. |
| ≤10-employee reliefs | Apply only to labelled datapoints. | Apply only to labelled datapoints. |
| Selected C information | May be added as supplementary information after Basic is complete. | C1-C9 form the selected Comprehensive Module and are reviewed as a whole. |
| Typical user need | Core counterparty dataset, management baseline or first formal report. | Broader lender, investor or corporate-client information needs. |
| Main claim risk | Treating Basic as a menu. | Making the claim with incomplete C disclosures or weak evidence. |
Why reporting options are often misunderstood
Teams commonly import assumptions from earlier VSME materials, customer questionnaires or other reporting frameworks. They then describe Option A as “minimum data” and Option B as “extra data”, without testing what the formal statement actually covers. The 2026 text makes the reporting route a B1 disclosure and links the statement to a whole-module rule. This means the claim is a controlled conclusion, not a cover-page preference.
The second source of confusion is the mixed datapoint architecture. A module can be applied in its entirety while certain fields remain voluntary, certain disclosures apply only when a stated fact exists, and specified fields are voluntary for an undertaking with 10 employees or fewer. “Entire module” describes the scope of the selected reporting route; it does not erase the labels inside the route.
Option A: Basic Module only
Option A is appropriate where the undertaking needs the B1-B11 dataset and can support every applicable part of it. It covers the reporting basis and entity profile, practices and policies, environmental metrics, workforce information and the corruption/bribery disclosure. It can serve as a standalone counterparty report or as the foundation for later expansion.
A defensible Option A process therefore includes more than a completed spreadsheet. It needs a documented perimeter, a datapoint inventory, applicability conclusions, methods and evidence, an index, and an approved B1 statement. If applicable B information is missing, the report should not use Option A merely because the missing data appear “advanced”.
Option B: Basic plus Comprehensive
Option B is appropriate where the undertaking needs and can support the wider C1-C9 dataset. C1-C2 deepen the business model and policies/targets; C3-C4 address climate targets, transition and risk; C5-C7 add workforce and human-rights information; C8 and C9 add specified activity exposure and governance diversity. The Basic Module remains part of the Option B report and should not be treated as an appendix that receives less review.
The strongest reason to use Option B is a genuine information need: for example, a bank requires climate-risk and policy information across its borrower portfolio, or a major customer wants a consistent full dataset from strategic suppliers. “More impressive” is not a sufficient reason if the undertaking cannot maintain the data annually.
Datapoint hierarchy: whole-module application preserves essential, if-applicable, voluntary, small-undertaking and sector/entity-specific classifications.
In practice
How the whole-module rule works
| Situation | Effect on the option claim |
|---|---|
| An essential datapoint is applicable and available but omitted without paragraph 22 basis. | The relevant module has not been completed; the Option A or B statement is not supported. |
| An if-applicable trigger does not exist and the conclusion is documented. | The disclosure may be absent and the module can still be applied in its entirety. |
| A datapoint is explicitly voluntary or introduced with “may”. | The undertaking can omit it without losing the module claim, though it may report it if useful. |
| A labelled datapoint is voluntary for an undertaking with 10 employees or fewer. | The undertaking may omit that labelled datapoint if the employee condition is satisfied and documented. |
| Information is omitted under paragraph 22. | The narrow omission conditions must be met, the affected disclosure identified in B1 and the decision reassessed each reporting date. |
| Sector- or entity-specific information is needed for relevance and faithfulness. | The undertaking should add appropriate metrics or narrative; the listed datapoints are not necessarily a ceiling for its own voluntary report. |
Selected C information under an Option A basis
Paragraph 25 provides a practical bridge: once B1-B11 have been completed, the undertaking may report selected disclosures from the Comprehensive Module. This allows a Basic report to respond to a focused lender or customer request without making a claim that all C1-C9 have been completed. The control is presentation: the B1 wording, disclosure index and section heading should all show that the C information is supplementary.
This is an implementation pattern rather than a third formal option. Avoid headings such as “Option A+”, “hybrid compliance” or “partial Option B”, because they can obscure the two options specified in B1.
Rule
RECOMMENDED DESCRIPTION
“The undertaking applies Option A (Basic Module). In addition, it provides selected information from C3 and C4 as supplementary disclosures in response to identified lender information needs. The undertaking does not state that it applies the Comprehensive Module in its entirety.”
A five-step option-selection process
1. Confirm eligibility, reporting period and the entity or group perimeter.
2. Complete the B1-B11 requirements and evidence matrix before choosing the public claim.
3. Identify the actual users and decisions the report must support: general counterparty response, lender due diligence, investor analysis, customer procurement or internal management.
4. Test whether the entire C1-C9 module can be supported. If only selected C information is needed, retain Option A and label the additions supplementary.
5. Approve the B1 wording, index, omissions and report location as one release decision.
In practice
Illustrative reporting statements
| Basis | Illustrative wording | What must support it |
|---|---|---|
| Option A | “This report has been prepared in accordance with Option A of the EU Voluntary Sustainability Reporting Standard, comprising the Basic Module.” | Complete B1-B11 matrix, applicability decisions, permitted omissions, index and approval. |
| Option B | “This report has been prepared in accordance with Option B of the EU Voluntary Sustainability Reporting Standard, comprising the Basic and Comprehensive Modules.” | Complete B1-B11 and C1-C9 matrices plus the same controls. |
| Option A with selected C | “This report applies Option A. Selected information from C3 and C4 is included as supplementary information and does not constitute application of the Comprehensive Module in its entirety.” | Complete Basic plus evidence for selected C and transparent index labels. |
| No formal option claim | “This response uses selected datapoints from the Commission-adopted Voluntary Standard. It has not been prepared as an Option A or Option B sustainability report.” | Accurate description of actual content, no implication of module compliance. |
Rule
ADAPTATION WARNING
These are illustrative structures, not official clauses. The undertaking must adapt the wording to the final legal title, its facts, reporting perimeter, omissions and approval process.
Hypothetical example: a diversified services group
In the following year, after the human-rights incident protocol, revenue mapping and governance-diversity calculation are approved, the group may reassess Option B. The change in reporting basis should be explained and comparatives considered under the Standard’s reporting principles.
Hypothetical scenario
ILLUSTRATIVE SCENARIO
A 260-employee services group completes B1-B11 on a consolidated basis. A bank requests C1, C2, C3 and C4, but the group has not completed C7 incident controls across all subsidiaries or the C8 revenue classification. The group should not select Option B merely because most environmental information is ready. It can apply Option A and provide the four selected C disclosures as supplementary information while it develops the remaining controls.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
Common reporting-claim errors
| Error | Why it fails | Better approach |
|---|---|---|
| Selecting the option at project kick-off | The statement is made before applicability and evidence are known. | Treat the option as a final release gate, while using a provisional route for planning. |
| Calling a Basic report “limited Option B” | The phrase is not one of the specified B1 options. | Use Option A and describe selected C as supplementary. |
| Treating voluntary fields as required for whole-module compliance | The datapoint labels are overridden. | Preserve each datapoint classification in the requirements register. |
| Hiding not-applicable disclosures | The reader cannot see the scope of the assessment. | Retain transparent index notes and internal applicability evidence. |
| Using paragraph 22 for ordinary data gaps | The omission categories are narrow and carry conditions. | Use estimates and limitation/remediation notes where possible; obtain specialist review for formal omissions. |
| Publishing a stronger claim than the counterparty response pack supports | Different outputs contradict one another. | Use one controlled basis statement across the report, index, portals and cover letters. |
Readiness
Option decision checklist
- The intended users and decisions are documented.
- B1-B11 have been completed and reviewed.
- Every datapoint classification is preserved.
- The ≤10-employee condition has been tested where relevant.
- The team has decided whether the full C1-C9 dataset is needed.
- Selected C disclosures, if any, are labelled supplementary.
- Every paragraph 22 omission is identified in B1 and supported.
- The disclosure index agrees with the public statement.
- The report wording is used consistently in customer and lender responses.
- Final legal status and numbering have been rechecked.
Sources
Primary sources
- · Commission Delegated Regulation C(2026) 5011 final (3 July 2026)
- · Annexes to C(2026) 5011 - Voluntary Standard and value-chain-cap list (3 July 2026)
- · Corporate Sustainability Reporting Directive - implementing and delegated acts (updated 3 July 2026)
- · Commission adopts revised sustainability reporting standards (3 July 2026)
- · Voluntary Standard - interactive text (2026)
- · Directive (EU) 2026/470 (Omnibus I) (24 February 2026)
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