EU Voluntary Standard Basic Module: Complete Guide to B1-B11 Disclosures

Basic Module architecture: B1-B11 form one reporting route, with datapoint-level conditions and reliefs.

The Basic Module is often described as the “simple” route. That description is useful only if it is not confused with a pick-and-choose questionnaire. The module is proportionate, but it still requires a controlled reporting basis, entity information, environmental and workforce data, and a transparent explanation of applicability. A weak first-year report usually fails not because the undertaking lacks every figure, but because it has not distinguished an essential datapoint from an if-applicable datapoint, a voluntary field or a formal omission.

The Basic Module also performs three jobs at once. It gives counterparties a standard dataset, helps the undertaking manage sustainability issues, and provides the prerequisite for any use of the Comprehensive Module. The resulting report therefore needs enough structure to support a formal reporting statement, a counterparty response and an evidence trail.

B1: establish the reporting basis before collecting metrics

B1 is the control centre of the report. It identifies Option A or Option B, states whether the report is individual or consolidated, lists subsidiaries in a consolidated report, identifies paragraph 22 omissions and provides entity information such as legal form, NACE codes, total assets, turnover, employee count, primary country of operations and significant sites. If certifications or labels have been obtained, the undertaking describes them under paragraph 28.

A reliable B1 process starts with a short reporting-basis memorandum approved before drafting. It should state the perimeter, period, route, employee test, site population, currency and units, any cross-references, and the owner of each omission decision. This prevents the index and the narrative from using inconsistent scopes.

B2: disclose what exists, not what a generic ESG template expects

B2 is conditional on the undertaking having put in place specific practices, policies or future initiatives. Where these exist, the undertaking states whether it has practices, sustainability policies, future initiatives or plans and targets for monitoring implementation. The wording should distinguish an approved policy from an operational practice and a current action from a future intention. A policy title without scope, owner or implementation evidence is rarely useful to a counterparty.

B3-B7: environmental metrics need a boundary and method

Environmental data often come from operational systems that were not designed for external reporting. For each metric, retain the reporting period, organisational and site boundary, unit conversion, estimation method, source record, data owner, reviewer and treatment of changes. B3 follows the GHG Protocol content for Scope 1 and location-based Scope 2. B4 is triggered by legal or EMS reporting, not by the mere existence of any emission. B5 requires a location-based screen. B6 distinguishes withdrawal from consumption. B7 combines narrative circular-economy information with waste and, for relevant sectors, material-flow data.

B8-B10: workforce metrics require definitions that match the HR systems

The workforce disclosures use employee information, so contractors and other non-employees should not silently enter the denominator. Decide whether headcount or full-time equivalents are used, define temporary and permanent contracts, reconcile geographic and gender totals, and document the denominator for accident rates and training averages. The B10 pay-gap datapoint is conditional: it is reported if the undertaking is already required by EU or national law to disclose it. It should not be treated as universally required solely because B10 is part of the module.

B11: an if-applicable governance metric

B11 applies where convictions and fines occurred during the reporting period. A “zero” disclosure can be useful if it has been supported by a formal legal or compliance confirmation, but the Standard’s if-applicable architecture means a report should avoid creating a false claim that every absence is independently assured. The evidence register should show who checked the relevant legal entities and period.

1. Lock the reporting basis: eligibility, reporting route, perimeter, period, employee test, units and authorisation process.

2. Create a datapoint inventory that records the classification attached to each B disclosure.

3. Test each if-applicable trigger using evidence rather than assumption.

4. Assign data owners and reviewers, then issue precise evidence requests with definitions and period.

5. Build methodology notes for energy, GHG, water, waste, workforce and any calculated ratios.

6. Draft the disclosure and index together so the location, status and omission wording remain aligned.

7. Run a cross-report consistency review against financial statements, regulatory returns and public claims.

8. Approve B1 and the final Option A or Option B statement only after every blocking item is closed.

Basic Module readiness matrix: a datapoint is ready only when applicability, evidence, ownership and review are traceable.

The reporting team calculates energy use and Scope 1 and location-based Scope 2 emissions, records total water withdrawal and water consumption for the production process, reports waste and workforce data, and obtains a written legal confirmation for B11. Because the undertaking has more than 10 employees, the targeted ≤10-employee reliefs do not apply. The report discloses its actual data gaps - for example, an estimate for fuel used in one leased vehicle - together with the method and improvement action.

Illustrative B1 wording

Why this works: it identifies the route, perimeter, period and omission status, while separating not-applicable conclusions from formal omissions. It does not claim assurance or imply that illustrative wording alone proves compliance.