A report I can’t quite assess

04 May 2026
Piotr Biernacki
Sustainability Managing Partner
"If you're the ones creating these standards, maybe you should try writing a report that actually complies with them!" — I've heard this expression of frustration from company representatives more than once. Fair point. An institution that develops standards should be confident that they are workable in practice. That isn't always the case, because within the Sustainability Reporting TEG and the EFRAG Board, company representatives are in the minority and don't always manage to persuade others to their positions. EFRAG took this advice to heart and published its first report compliant with the VSME standard. Does this make it a model for all reports based on that standard? Frankly, I find it difficult to assess EFRAG's report.

EFRAG's report is available at this address. As best practice dictates, it is an HTML file tagged with XBRL markup, wrapped in a viewer that allows navigation through the individual elements of the report and the data they contain (try the panel on the right-hand side). EFRAG used its own tool, developed and made freely available to anyone wishing to tag their VSME-compliant reports with XBRL, to tag the report.

Note: spoilers ahead. I encourage you to read, or at least skim through, EFRAG's report on your own before reading my take below.

So what exactly is my problem with assessing this report?

EFRAG's report is fully compliant with VSME. At the same time, it is not particularly clear and contains immaterial information. I found it difficult to read. But not because mistakes were made in preparing it; rather because its authors stuck strictly to the standard.

A few examples:

  • A full half-page is devoted to indicator B9 solely to convey something that could be expressed in a single sentence: "No workplace accidents occurred in 2025."
  • From indicator C8 I learned that EFRAG is not excluded from any EU reference benchmarks aligned with the Paris Agreement. Seriously? An organisation involved in developing standards, with an entirely office-based business model? I wasn't expecting that. 😉
  • Indicator B2, in turn, informs me that several sustainability topics (climate change, water and marine resources, circular economy, own workforce, and business conduct) are addressed through policies, practices, or future initiatives that are publicly available. Which of these topics are covered by formal policies, which by operational practice, and which EFRAG plans to address in the future - that I could not determine. Nor where to find more information online. Admittedly, on the next page I found indicator C2 with a more detailed description, but I still found it difficult to connect the management approaches to those topics with any publicly available documents.

The examples above do not arise from any errors in preparing the report. On the contrary, no errors were made; the report is fully, completely, and very precisely compliant with VSME. And that is precisely why these oddities appear in it.

VSME is a set of very basic and fairly limited ESG indicators. If followed literally, the result is a report that is hard to regard as fluid or as telling a story about the reporting entity. Above all, there is no sense of materiality. As you might imagine, EFRAG has a very limited impact on the natural environment. Its impact on its own employees is considerably greater. And its greatest impact, above all, is on other actors in the value chain (experts collaborating with EFRAG and participating in consultations, and the thousands of companies that use EFRAG's information, standards, and materials in their reporting activities), although they are mentioned in just a single paragraph.

I am very pleased that EFRAG took on the task of preparing its own VSME-based report. I believe it will contribute to the development of better implementation tools for all companies in the future. And I encourage you to read the report. If you feel like it — write to me and let me know what you think. 😊

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