How to Prepare a Report Under the EU Voluntary Standard: Step-by-Step Guide

From user and request mapping to module selection, data ownership, evidence, calculations, review and release

The Voluntary Standard is deliberately proportionate, but it still combines corporate information, environmental metrics, workforce data, policies, climate information and business-conduct disclosures. A team that starts with the template can collect too much, overlook an applicable condition, use inconsistent reporting periods or make a formal compliance statement before the supporting evidence has been reviewed.

A well-designed project starts with the decisions the report must support. The same undertaking may need a concise Basic Module response for a customer, a fuller package for a bank, an internal management dashboard and a public report. These uses can share data and evidence, but they do not automatically require the same output, level of detail or publication route.

The standard's primary function is to inform actual or potential business counterparties. An undertaking may also publish the report publicly, but public publication is a choice rather than an automatic requirement of the Voluntary Standard. Start by registering who is asking, why the information is needed, when it is needed and whether the request is recurring.

1. Confirm whether the undertaking is subject to mandatory sustainability reporting under Articles 19a or 29a of the Accounting Directive. A mandatory reporter should not substitute the Voluntary Standard for ESRS.

2. Identify the responding legal entity and record its employee status. Annex I states that the standard is intended for undertakings that do not exceed an average of 1,000 employees during the preceding financial year.

3. Choose individual or consolidated reporting. A parent is recommended to report on a consolidated basis; subsidiaries included in that consolidated report are exempted from separate reporting under the Voluntary Standard.

4. Fix the reporting period. Where the undertaking prepares financial statements, the sustainability period should be consistent with them. From the second reporting year, comparative information is required except for metrics disclosed for the first time.

5. Decide whether the report will be annual. It is required annually where it is prepared to meet annual update needs of large undertakings or banks; otherwise the reporting cadence should be agreed and disclosed.

Annex I paragraph 25 permits an undertaking that has completed B1-B11 to add selected disclosures from the Comprehensive Module. B1 paragraph 27, however, says that a selected module is to be complied with in its entirety. The defensible reading is that selected C disclosures may be added as voluntary information, while a formal Option B statement should be reserved for a complete Comprehensive Module, subject to applicable conditions and permitted omissions. This is an LRA technical interpretation that should be confirmed during final review.

Do not use a single yes/no column for the whole Standard. Classify every datapoint by its status and the facts that activate it. The matrix should distinguish essential datapoints, information required only if specified circumstances apply, voluntary information, sector considerations and datapoints that are voluntary for undertakings with 10 employees or fewer.

Figure 1. LRA implementation pathway: the same six reporting stages can be delivered through an accelerated 90-day project or a six-month system-building programme. It is not an official EU timetable.

A hypothetical components manufacturer has 180 employees. Two customers request emissions, water, workforce and human-rights data; its bank also requests climate targets and risk information. The company chooses Option B because the requests are recurring and it already has reliable utility, HR and compliance data. It maps each disclosure, identifies that Scope 3 is a sector consideration rather than an Annex II cap item, and separates the bank's credit-risk request from customer CSRD requests.

The first draft reveals inconsistent site boundaries between energy and water data. Finance and EHS agree a site register, the GHG workbook is recalculated, and the limitation is removed before approval. The company releases a public report and a controlled counterparty data extract, both linked to the same evidence register.

Starting with a generic ESG questionnaire rather than a controlled user and purpose register.

Selecting Option B because it appears more credible, without resources to complete and review the module.

Treating 'if applicable' as an undocumented opt-out rather than a factual conclusion.

Combining entities, sites or periods differently across energy, water, HR and revenue metrics without reconciliation.

Using unapproved targets, policies or benefit claims in the narrative.

Publishing before the delegated regulation enters into force without a status-qualified basis-of-preparation note.

Assuming that a voluntary report must be publicly available or independently assured.