Short answer
The answer, before the reasoning
Choose the Basic Module when the organisation needs a reliable core report, is building its first repeatable data cycle or mainly answers proportionate customer and management questions. Choose Basic plus Comprehensive when banks, investors or corporate clients need additional information on strategy, policies, Scope 3, GHG targets, transition, climate risks, workforce depth, human rights, sensitive activities or governance diversity - and the organisation can complete and evidence the full Comprehensive Module.
Basic B1-B11 is always a prerequisite. Paragraph 25 permits selected Comprehensive disclosures after B1-B11, but a cautious approach is to label them as supplementary information and retain Option A until C1-C9 are complete. Size matters, including special ≤10-employee reliefs, but purpose and data maturity should drive the choice.
Why the choice matters
Choosing too little can leave banks or key customers without decision-useful information. Choosing too much can create fragile estimates, unsupported narratives and a report that cannot be repeated next year. The right choice is therefore the smallest module architecture that fully supports the priority users and can be governed with reliable data and evidence.
The decision should be made before drafting. It affects the data request, reporting calendar, owners, climate and human-rights workstreams, external review effort and wording of the compliance statement. It also affects whether the report can serve as a reusable baseline or becomes a one-off questionnaire response.
Quick orientation
- Applies to
- Undertakings within the intended population that have confirmed voluntary use and need to select Option A or Option B.
- Primary decision
- Which module best fits company size, information users, data maturity, climate needs and upgrade plans.
- Key sources
- Annex I paragraphs 6-8, 24-64 and B1 paragraph 27.
- Common confusion
- The Comprehensive Module is not a standalone option, and selected C disclosures do not automatically mean the full Comprehensive Module has been applied.
1. The two options in B1
Paragraph 27 says a selected module must be complied with in its entirety. Paragraph 25 says an undertaking that has completed B1-B11 may additionally report disclosures selected from the Comprehensive Module. Read together, these provisions support a staged path, but the module statement should remain precise. A report can be useful and extensive without claiming Option B prematurely.
In practice
| Option | Content | Statement design — Primary use |
|---|---|---|
| Option A | Basic Module only: B1-B11. | State compliance with the Basic Module and identify any permitted omissions. — Core reporting, first year, micro-undertakings, standard customer response and internal management. |
| Option B | Basic Module plus Comprehensive Module: B1-B11 and C1-C9. | State compliance with both modules only after full module review. — Additional bank, investor and corporate-client information needs. |
| Option A + supplements | B1-B11 plus selected C disclosures or other additional information. | Describe additional disclosures as supplementary; do not imply full Option B unless completed. — Staged transition or targeted user need. |
2. What the Basic Module covers
For undertakings with 10 employees or fewer, several environmental datapoints in B3, B6 and B7 are explicitly voluntary. The undertaking should still record whether it used the relief and whether the information is available or useful for a bank or customer. Voluntary does not mean prohibited.
In practice
| Disclosure | Decision-useful content | Typical source owner |
|---|---|---|
| B1 - Basis for preparation | Module, omissions, individual/consolidated basis, subsidiaries, legal form, NACE, assets, turnover, employees, operations, assets, sites and certifications. | Finance, company secretariat, group reporting. |
| B2 - Practices, policies and future initiatives | Existing practices, policies, plans and targets for sustainability issues. | Sustainability, operations, HR, compliance. |
| B3 - Energy and GHG | Energy consumption, available renewable/non-renewable breakdown, Scope 1 and location-based Scope 2. | Facilities, energy, environmental team. |
| B4 - Pollution | Pollutants reported to authorities or under an environmental management system. | Environmental compliance. |
| B5 - Biodiversity | Sites/locations in or near biodiversity-sensitive areas and the BSA name. | Property, environment, GIS. |
| B6 - Water | Withdrawal, relevant production-process consumption and water-stressed-site consumption. | Operations and environmental team. |
| B7 - Circular economy and waste | Circular principles, waste, diversion to recycling/reuse and relevant material flows. | Operations, waste and procurement. |
| B8 - Workforce profile | Employees by contract, gender and country. | HR/payroll. |
| B9 - Health and safety | Recordable accidents, rate and fatalities subject to legal restrictions. | H&S and HR. |
| B10 - Pay, bargaining and training | Minimum-wage position, applicable pay gap, collective bargaining and training hours. | HR/payroll/legal. |
| B11 - Corruption and bribery | Convictions and total fines in the reporting period. | Compliance/legal. |
3. What the Comprehensive Module adds
Figure 1. Basic and Comprehensive selection matrix by purpose, content, effort, climate depth and upgrade path.
In practice
| Disclosure | Additional decision use | Why it often needs more maturity |
|---|---|---|
| C1 - Business model and strategy | Products/services, markets, business relationships and sustainability-related strategy elements. | Requires a coherent narrative and approved business-model description. |
| C2 - Detail on policies and initiatives | Scope, targets and senior accountability for practices and policies already identified under B2. | Needs policy inventory, target register and governance evidence. |
| Scope 3 consideration | Significant upstream and downstream emissions categories where relevant. | Requires category screening, estimates, suppliers and methodology. |
| C3 - GHG targets and transition | Target/base years, scope coverage, actions and high-climate-impact transition information. | Needs approved targets, baseline control and action plan. |
| C4 - Climate risks | Hazards, transition events, exposure/sensitivity, horizons, adaptation and optional financial-effect rating. | Requires risk process, asset/value-chain assessment and governance. |
| C5 - Workforce depth | Turnover, management gender ratio, self-employed and agency-worker information. | Needs broader workforce definitions and source reconciliation. |
| C6-C7 - Human rights | Policies, coverage, complaints mechanisms and confirmed incidents in workforce/value chain. | Needs legal/privacy review, incident governance and controlled evidence. |
| C8 - Certain revenues | Revenues from prohibited weapons, tobacco, fossil fuels and specified chemicals production. | Needs activity classification and finance reconciliation. |
| C9 - Governance diversity | Gender diversity ratio in the governance body. | Needs governance-body definition and approved source. |
4. The climate difference between the modules
Climate information is often the deciding factor. The Basic Module establishes energy, Scope 1 and location-based Scope 2 information. Depending on activities, Scope 3 can be appropriate as additional information, and if provided it should cover significant categories based on the GHG Protocol approach. The Comprehensive Module then adds formal GHG targets, transition-plan information for high-climate-impact sectors and climate-risk disclosures.
In practice
| Climate question | Basic response | Comprehensive response / residual work |
|---|---|---|
| What energy and direct/purchased-energy emissions exist? | B3 total energy, available breakdown, Scope 1 and location-based Scope 2. | Same core data, with stronger methodology and user explanation where needed. |
| Are value-chain emissions significant? | Scope 3 can be added under paragraphs 49-52 when relevant. | Screen all 15 categories; report significant categories with methods and limitations. |
| Does the company have reduction targets? | B2 can identify targets generally. | C3 requires target/base years, values, units, scope coverage and main actions. |
| Does it have a transition plan? | Not a core Basic metric. | C3 addresses adopted plans or timing for adoption in high-climate-impact sectors. |
| What climate risks affect the business? | May be discussed as additional relevant information. | C4 addresses hazards, transition events, exposure/sensitivity, horizons and adaptation. |
| What are financial effects? | No full mandatory financial-effects model. | C4 permits a high/medium/low assessment; lenders may still need additional quantified credit information. |
In practice
5. Selection matrix by company size, maturity and purpose
| Situation | Likely starting option | Why — Upgrade trigger |
|---|---|---|
| ≤10 employees; first report; simple customer needs | Option A using applicable micro reliefs. | Lowest proportionate starting point; focuses on reliable core facts. — A bank/customer needs C fields or data maturity improves. |
| 11-250 employees; recurring supply-chain questionnaires | Option A, possibly with selected supplements. | Builds a reusable core without claiming full C1-C9. — Repeated requests cluster around strategy, climate or human rights. |
| 251-1,000 employees; multiple lenders and strategic customers | Option B if C1-C9 evidence is available; otherwise controlled staged upgrade. | Information users are more likely to need the Comprehensive layer. — Governance approves complete C workstreams and evidence. |
| High-climate-impact business with transition-finance needs | Option B is often more useful. | Targets, transition and climate-risk information may be decision-critical. — Scope 3, target and risk controls pass review. |
| Professional-services business with limited environmental footprint | Option A may be sufficient, with workforce/governance supplements. | User needs may centre on people, policies and business conduct. — Finance/customer requests require C6-C9 or climate risk. |
| Company preparing eventual mandatory reporting | Option B as a bridge, but not as a claim of ESRS equivalence. | Builds governance and data depth while remaining proportionate. — Formal ESRS gap assessment and mandatory-scope trigger. |
6. How to test bank and customer expectations
Do not choose Option B simply because a bank is involved. Convert stakeholder requests into an information-needs matrix. Some banks may need only B1, B3, B8-B11 and a few C3/C4 fields. Others may need sensitive-activity, human-rights or transition information. The module decision should consider recurring common needs, not the longest single questionnaire ever received.
In practice
| Question to ask the user | Why it matters |
|---|---|
| Which decision will the information support? | Credit, procurement, investment, engagement and public reporting use different thresholds of detail. |
| Which fields are genuinely required versus preferred? | Prevents a voluntary “nice to have” from driving a full module unnecessarily. |
| Will a Standard-based report replace the questionnaire? | Determines reuse value and residual custom fields. |
| What period, boundary and update frequency are needed? | Avoids producing a report that cannot be used in the decision window. |
| Are estimates acceptable, and what methodology is expected? | Shapes Scope 3, climate-risk and workforce data work. |
| Will information remain confidential or be benchmarked/published? | Changes approval, privacy and disclosure wording. |
| Does the user accept selected C supplements without Option B? | Supports a staged route while preserving claim accuracy. |
7. A five-stage upgrade path
Figure 2. Controlled upgrade from scoped reporting to a complete Option B report.
In practice
| Stage | Work performed | Release rule |
|---|---|---|
| 1 - Scope and users | Confirm eligibility, legal status, report boundary, period, intended audiences and priority decisions. | No module promise before scope approval. |
| 2 - Reliable Basic | Complete B1-B11, applicability decisions, micro reliefs, evidence and review. | Option A may be released when all applicable Basic requirements are satisfied. |
| 3 - Comprehensive gap analysis | Map C1-C9 to source systems, policies, targets, risk processes and user requests. | Open gaps have owners and target dates. |
| 4 - Selected supplements | Add high-value C disclosures or additional information with clear labels. | Remain Option A unless the full Comprehensive Module is complete. |
| 5 - Option B gate | Complete C1-C9, resolve limitations, review claims and obtain approval. | Only then state compliance with Basic and Comprehensive modules. |
In practice
8. Evidence and controls by module
| Control area | Basic minimum | Additional for Comprehensive |
|---|---|---|
| Entity and boundary | Legal entity/group list, period, sites, employee and turnover data. | Business relationships, markets, products/services and strategy governance. |
| Environmental data | Utility, fuel, GHG, pollution, water, waste and location evidence. | Scope 3 screening, target baseline, transition actions and climate-risk assessment. |
| Workforce | Payroll/headcount, contract, gender, country, accidents, pay, bargaining and training. | Turnover, management ratio, non-employees, policies, mechanisms and incident controls. |
| Finance | Assets, turnover, fines and sensitive-activity reconciliation where applicable. | C8 revenue classification and link to finance/credit analysis. |
| Governance | Policy owners, approvals, corruption data and report sign-off. | Senior accountability, governance diversity and cross-functional target/risk oversight. |
| Review | Requirement-level completion, applicability and omission review. | Model and judgement review for Scope 3, climate risk, incidents and strategic narrative. |
In practice
9. Hypothetical module choices
| Organisation | User need and maturity | Decision |
|---|---|---|
| 12-employee food distributor | Customers want workforce, energy and waste information; no formal climate targets. | Option A. Build reliable B1-B11 and reassess C fields next year. |
| 180-employee manufacturer | Two lenders require GHG targets, transition actions and physical climate risks; data systems are mature. | Option B if C1-C9 can be completed; Scope 3 screening included. |
| 60-employee consultancy | Strong workforce data; client asks for human-rights policy and governance diversity. | Option A plus selected C6/C9 supplements, clearly labelled, until full C1-C9 is ready. |
| 8-employee engineering studio | Wants a public sustainability profile but has limited environmental data. | Option A using ≤10 reliefs; report available facts and avoid generic green claims. |
| 900-employee logistics group | Multiple strategic customers, climate risks and finance needs; group data definitions vary. | Staged route: consolidated Basic first, group controls and C gap closure, then Option B gate. |
10. Illustrative module statement
This wording is useful only if the Basic Module is complete, the supplements are accurately identified and the legal status is separately explained. It is not a universal template and should be adapted to the final OJ text, facts and user needs.
In practice
11. Common mistakes
| Mistake | Consequence | Correction |
|---|---|---|
| Selecting Option B for prestige | Creates incomplete C disclosures and weak evidence. | Use the smallest complete option that meets priority user needs. |
| Treating Comprehensive as standalone | Omits the required Basic foundation. | Complete B1-B11 first. |
| Assuming company size determines the module | Ignores climate, finance, customer and maturity needs. | Use a size-maturity-purpose matrix. |
| Calling a selected C disclosure “Option B” | Overstates module compliance. | Label supplements and retain Option A until all C1-C9 are complete. |
| Using “not applicable” for every missing field | Hides voluntary, micro-relief, omission and data-gap distinctions. | Use controlled status codes and explain limitations. |
| Ignoring repeatability | Produces a one-off report that cannot be updated. | Build source owners, methods, controls and a next-year calendar. |
| Assuming Option B equals ESRS | Creates false equivalence. | Perform a separate ESRS gap assessment for mandatory or broader reporting. |
Readiness
12. Module selection checklist
- Eligibility, intended population and current legal status are confirmed.
- Priority users and their actual decisions are documented.
- The recurring common information need is distinguished from one-off custom questions.
- Basic B1-B11 data sources and owners are assessed.
- Comprehensive C1-C9 gaps are mapped before Option B is selected.
- ≤10 employee voluntary fields are correctly identified.
- Climate needs cover energy, Scope 1/2, Scope 3 relevance, targets, transition and risks as appropriate.
- Human-rights and incident disclosures have legal/privacy controls.
- Selected C supplements are labelled without an Option B overclaim.
- The module statement is reviewed at requirement level.
- Report, bank and customer outputs reconcile to one source register.
- An approved upgrade plan exists where the current option is temporary.
Option B does not make a report equivalent to ESRS. It combines the Basic and Comprehensive Modules and can provide a bridge to wider reporting needs, but ESRS has its own legal scope, materiality logic, disclosure requirements and compliance basis.
Self-check
- Could the reporting team evidence every disclosure included in the selected module?
- Would the same module still be selected if the longest one-off questionnaire were removed?
- Are selected Comprehensive supplements clearly different from a full Option B claim?
- Can the organisation update the chosen option next year without rebuilding the data system?
Questions
Questions people ask
Is the Basic Module only for micro-undertakings?
Choose the Basic Module when the organisation needs a reliable core report, is building its first repeatable data cycle or mainly answers proportionate customer and management questions. Size matters, including special ≤10-employee reliefs, but purpose and data maturity should drive the choice.
Can an undertaking apply the Comprehensive Module without Basic?
Paragraph 25 says an undertaking that has completed B1-B11 may additionally report disclosures selected from the Comprehensive Module. Read together, these provisions support a staged path, but the module statement should remain precise. A report can be useful and extensive without claiming Option B prematurely.
Can a company publish selected C disclosures while using Option A?
Basic B1-B11 is always a prerequisite. Paragraph 25 permits selected Comprehensive disclosures after B1-B11, but a cautious approach is to label them as supplementary information and retain Option A until C1-C9 are complete.
Does Option B make the report equivalent to ESRS?
Option B does not make a report equivalent to ESRS. It combines the Basic and Comprehensive Modules and can provide a bridge to wider reporting needs, but ESRS has its own legal scope, materiality logic, disclosure requirements and compliance basis.
Sources
Primary sources
- Commission Delegated Regulation C(2026) 5011 final
- Annex I - Sustainability reporting standard for voluntary use
- Annex II - Datapoints covered by the value-chain cap
- Directive (EU) 2026/470
- Commission Recommendation (EU) 2025/1710
- EFRAG VSME Standard and implementation resources
- European Commission adoption announcement, 3 July 2026
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