FAQ on the VSME report

Your questions about VSME – our answers

Here you will find answers to the most frequently asked questions about the Voluntary Sustainability Reporting Standard for SMEs (VSME):

  • Further development of the DNK from a reporting standard to a support service for CSRD-compliant sustainability reporting
  • Information for SMEs
  • Support services during the transition period between the old and new DNK
  • Using the new DNK web platform
  • DNK guides
  • Further information
  • DNK declaration in the old DNK database

Please note: The DNK is currently undergoing further development. In this context, we are constantly working on adjustments and enhancements to our offering in order to incorporate new information, steps and findings.  We therefore ask you to always check the status of the information provided, as this FAQ is continuously updated to reflect the latest developments.

Further development of the DNK from a reporting standard to a support service for CSRD-compliant sustainability reporting

Here you will find answers to frequently asked questions about our further development.

Yes, the DNK will continue to exist. Since the beginning of 2025, we have been offering comprehensive support for CSRD-compliant sustainability reporting instead of a reporting standard. With our new DNK platform, companies can create their complete CSRD report digitally free of charge and make use of numerous application aids.

(As of 15 November 2024)

With the DNK checklist, we offer you clear and practical guidance for implementing the ESRS reporting requirements. We have compiled over 1,000 data points for you in a clear and understandable structured checklist, clearly marking mandatory and voluntary information and simplifying complex wording and technical terms.

Find out more here: DNK Checklist

(as of 29 January 2025)

The new DNK offering differs from other offerings in four key ways:

 

  • Free of charge: Our offerings are available free of charge to both companies that are required to report and those that report voluntarily, and are aimed in particular at small and medium-sized enterprises (SMEs) that cannot afford comprehensive consulting services due to a lack of resources.
  • Needs-oriented: Through close cooperation with various stakeholders, we have gained deep insight into the specific needs of German companies, especially SMEs. This enables us to offer a particularly needs-oriented and user-friendly reporting tool.
  • Expertise: The DNK has been in existence since 2011 and therefore has extensive experience in the field of sustainability reporting. This experience is incorporated into the further development of our services and is intended to provide support to companies.
  • Initial consultation: A free initial consultation is available by email or telephone. Beyond an initial consultation, we do not offer individual advice and refer clients to DNK guides. However, they work independently of the DNK, on their own responsibility, and invoice their services individually.    

(As of 12 March 2024)

The new DNK platform enables you to generate customised reports based on your materiality analysis. When you start creating your report, you can enter the results of your materiality analysis into the DNK platform. An input mask will be provided for this purpose, in which you can mark the reporting content that is material for your company at the level of ESRS topics, sub-topics and sub-sub-topics. The data points to be reported are automatically assigned based on this selection. If you are at the beginning of your materiality analysis, you can download an Excel template in the future. With this template, you can mark content to be reported during the materiality analysis. The template can be uploaded to the DNK platform after finalising the materiality analysis so that a customised report structure is generated.

 

We offer the following support services:

 

 

The network of DNK guides is available to provide you with individual advice.

 

Please note that the materiality analysis process should be reviewed and approved by your auditing firm prior to implementation, as it will also be audited.

(As of 23 July 2025)

Information for SMEs

Here you will find answers to frequently asked questions specifically for small and medium-sized enterprises (SMEs).

The VSME module will be available from September 2025. We currently offer a gap analysis to help identify the differences between the previous DNK and the VSME. A fillable VSME input form is also available on the DNK platform, which contains the relevant VSME data points. 

(As of 23 July 2025)

Companies that are already registered can continue to work in the old DNK database until the end of December 2026. DNK declarations can be submitted to the old database until 30 November 2026, and the review of reports, including feedback loops, must be completed by 31 March 2027. From April 2027 onwards, reports can only be viewed and downloaded.

We recommend that you start preparing for VSME reporting now using the DNK's transitional solutions. If you would like to start preparing for VSME reporting now: Until the VSME module for SMEs is available, we offer a gap analysis to help you identify the differences between the previous DNK and the VSME. A fillable VSME input mask containing the relevant VSME data points is also available on the DNK platform.  

If you start the report directly in the new VSME module on the DNK platform: Once the VSME module has been made available in September 2025, the previous reports can be transferred to the new DNK platform and reporting can take place in accordance with the VSME on the DNK platform. There will also be a check to ensure that the voluntary reports are formally complete in accordance with the VSME.

(As of 23 July 2025)

The EU Omnibus is still only a proposal and has not yet been finally adopted. Changes are still possible, meaning that smaller companies could ultimately be required to report after all. It would therefore be unwise to stop preparations at this early stage.

Regardless of legal requirements, it is becoming increasingly important for companies to focus strategically on sustainability. Investors, customers and business partners are increasingly expecting transparency. Companies that address sustainability reporting at an early stage are investing in their future viability and competitiveness.

With our new VSME module, which is currently under development, we are providing targeted support to companies that are not subject to reporting requirements in applying the voluntary VSME reporting standard.

(As of 12 March 2025)

In principle, data entered is not lost during iterations of the platform. However, it cannot be ruled out that individual data records cannot be assigned to new development statuses. Particularly in the current phase, in which adjustments can still be made to the data points, it is advisable for companies to save all information entered so that they have a backup.

(As of 12 March 2025)

Support services during the transition period between the old and new DNK

Here you will find answers to frequently asked questions about our support services for the transition period.

The existing reporting requirements under the German Sustainability Code (DNK) provide a solid basis for developing CSRD reporting thanks to their existing content and structures (e.g. responsibilities for data collection and knowledge of disclosure requirements for specific topics).

However, we recommend that you only finalise reports that have already been started and do not submit any new reports to the old DNK database, as reporting will be possible in the new VSME module from September 2025.

 

For companies subject to mandatory reporting

Reports in accordance with CSR-RUG must be submitted for review by 30 November 2026 at the latest. From 1 April 2027 onwards, reports can only be viewed and downloaded via the old database in the login area.

 

For companies reporting voluntarily

Companies that report voluntarily can also submit their DNK declarations for review until 30 November 2026. From 1 April 2027, reports can only be viewed and downloaded via the old database in the login area.

Your data will not be lost: you can download all DNK declarations from previous years. Your company information and the report content of the current DNK declaration can also be transferred to the new DNK platform.

(As of 23 July 2025)

Companies that are already registered can continue to work in the old DNK database until the end of November 2026. DNK declarations can still be submitted to the old database until 30 November 2026, and the review of reports, including feedback loops, must be completed by 31 March 2027. From April 2027 onwards, reports can only be viewed and downloaded.

(As of 23 July 2025)

Using the new DNK platform

Here you will find answers to frequently asked questions about the terms and conditions of our new platform.

The early access version of the new DNK platform enables companies to create their sustainability reports digitally and be guided step by step through the reporting process. This version is already functional and contains extended features compared to the beta version (all details can be found in the changelog PDF). 

As we are continuously optimising the platform, particularly with regard to possible changes to the CSRD as a result of the EU Omnibus Package, it is undergoing ongoing development. Users of the early access version will therefore benefit from the latest features and improvements at an early stage.

(As of 14 March 2025)

An overview of current features, fixed bugs, features in development, and planned future features can be viewed here or within the platform by clicking on the Early Access Version emblem.

(As of 14 March 2025)

The new DNK platform will initially focus on reporting in German. The option to report in other languages may become available in the future.  

(As of 12 March 2024)

The following options can be displayed on the platform:

 

  • Description of the company or group structure
  • (Multiple) individual reports per company/subsidiary
  • As an alternative to individual reports, a consolidated sustainability report at group level

 

(as of 15 November 2024)

No, publication is voluntary.

(As of 15 November 2024)

The Omnibus Package on Sustainability Reporting is an initiative by the European Commission to simplify and harmonise existing regulations in the area of sustainability reporting and corporate responsibility. The package includes amendments to several directives and regulations, including the CSRD and the CSDDD. Key measures include reducing reporting requirements for smaller companies, postponing deadlines and simplifying standards.

On 26 February 2025, the European Commission presented a draft of the package, which has not yet been finally adopted. Changes are still possible, meaning that smaller companies could end up being subject to reporting requirements after all. It would therefore be unwise to stop preparations at this early stage. Even if fewer companies are formally required to report in future, we expect that more and more SMEs will report voluntarily. Investors, customers and business partners increasingly expect transparency on sustainability issues. With our new VSME module, which we are currently developing, we are providing targeted support to companies that report voluntarily in applying the VSME reporting standard.

Regardless of possible regulatory changes, the DNK remains a reliable partner for sustainability reporting – both for companies that are required to report and those that report voluntarily.

(As of 12 March 2025)

Our offering has a modular structure: the first module is aimed at companies subject to reporting requirements. A second module for companies that report voluntarily is currently under development. The VSME module will be available from September 2025. Our goal is to tailor the VSME module optimally to the needs of users.

For the transition, we offer companies a gap analysis to help identify the differences between the previous DNK reporting standard and the VSME. In addition, a fillable VSME input form is available on the DNK platform, which contains the relevant VSME data points.  

(As of 23 July 2025)

DNK guides

Here you will find answers to frequently asked questions about DNK guides.

Against the backdrop of the further development of the DNK and the integration of the new EU standards, the existing concept and implementation of the ‘DNK guides’ (formerly training partnerships) is currently being further developed.  

The new requirements for DNK guides will place a stronger focus on sustainability reporting in accordance with CSRD and the experience and desired service portfolio of consulting firms.  

There will be a transitional solution for existing network partnerships in 2025. The guides will be informed accordingly by the DNK team.  

The following quality criteria apply for admission to the guide network:

  • Application form for self-disclosure (including presentation of previous projects, consulting focus areas and CSRD experience)
  • Proof of at least three years of experience in sustainability consulting with a focus on reporting
  • Creation and publication of your own VSME report on the DNK platform and its update every two years
  • Regular participation in DNK training courses (next training course expected in October 2025)
  • Active participation in the network, for example by attending the annual meeting of all DNK guides (digital or on-site)
  • Agreement to the Code of Conduct as a framework for our trusting network cooperation

Newly interested guides are welcome to contact us at support@deutscher-nachhaltigkeitskodex.de. Admission to the network is free of charge, subject to verification of requirements and fulfilment of criteria, and does not constitute certification. Participating DNK guides receive their own logo to communicate their network membership to the outside world. The logo shows that they meet the network's current quality requirements. It is reissued annually after the criteria have been reviewed.

Would you like to become part of the DNK guide network? The admission process for 2026 will start in November after the VSME module has been published. You will find the new application form for self-disclosure here in due course.

(As of 26 August 2025)

Further information

Here you will find answers to frequently asked questions for further information.

The Sustainability Campus offers a wide range of support services from the DNK. It accompanies you on your way to completing your sustainability report and provides you with a free initial consultation by telephone and email. For further, individual advice, you can draw on the network of DNK guides. In addition, a comprehensive, practical range of information and training on sustainability reporting in accordance with CSRD is available – from webinars and explanatory videos to helpful documents such as guidelines and fact sheets.

Find out more here: DNK Sustainability Campus

In principle, our new DNK platform can also be used by non-German companies. The content of the platform is in German. However, we refer to the German implementation law when implementing it. Country-specific interpretations are therefore not taken into account.

(As of 15 November 2024)

DNK declaration in the old DNK database

Here you will find answers to the most frequently asked questions about the current DNK database and the DNK as a reporting standard.

That depends entirely on how deeply sustainability is already anchored in the company and to what extent the necessary data and facts are already available in processed form.

Our 2018 user survey showed that the time required to prepare the DNK declaration varies greatly, averaging around 21 days. However, even a significant time investment is worthwhile if the process helps the company clarify its sustainability strategy, the goals it wants to set and the measures it will take to achieve them.

The application of the DNK is free of charge. The internal costs for the company depend on the time required to obtain the data.

The review of a DNK declaration by the DNK office relates exclusively to the formal requirements of the DNK and serves primarily to provide procedural support to the report authors. The DNK office accepts no liability for the quality, completeness, timeliness and accuracy of the information contained in the DNK declarations or for compliance with the legal requirements of the reporting obligation under the CSR Directive Implementation Act (CSR-RUG) and the EU Taxonomy Regulation. Responsibility for the accuracy and quality of non-financial declarations and reports and for compliance with the legal requirements under the CSR-RUG and within the meaning of the EU Taxonomy Regulation lies solely with the companies.

The RNE therefore does not issue a certificate.

If companies wish to increase the credibility of their DNK declaration, the German Council for Sustainable Development (RNE) recommends having the content of individual or all information in the DNK declaration reviewed by an external auditor. This audit should be based on common standards (such as the International Standard on Assurance Engagements (ISAE) 3000 Revised or the Eco-Management and Audit Scheme (EMAS)). A content review of individual or all information in the DNK declaration can be carried out by auditors, EMAS environmental verifiers or other suitable audit service providers. If a content review is carried out by auditing firms, it can be carried out with reasonable assurance or limited assurance for the audit opinion. However, the RNE recommends that statements in the DNK declaration be audited with reasonable assurance, as is the case with the management report.

The presentation of information in sustainability reports does not appear to be suitable for potential users in the capital market, as it lacks comparability and quantification in particular. For this reason, the German Council for Sustainable Development, together with representatives of the capital market, has selected a set of performance indicators from common reporting standards and described criteria. This provides a concise and clear overview of the key information on a company's sustainability performance. In addition, it can be assumed that much of the information required for the DNK declaration is already available if your company has already published a sustainability report.

Companies share responsibility for sustainable development. They should document how they fulfil this responsibility to the public. The capital market in particular is increasingly using this information to assess the opportunities and risks of capital investments and lending more comprehensively.

But reporting also has a strong impact on the company itself: reporting is not just about collecting data, but also about taking a close look and analysing. This reveals weaknesses, but also untapped opportunities. The company can see whether it is complying with all laws and regulations (compliance).

Another important effect is that the workforce becomes more aware of and motivated to act sustainably. In addition, companies show how they are working together with politicians and society to achieve overall sustainable development. This task requires the involvement of all partners. German sustainability policy and the national sustainability strategy potentially provide a sounding board for corporate contributions to sustainability.

By reducing the focus to the essential aspects, the DNK supports the clear and comparable presentation of a company's sustainability performance.

The German government wants to use the National Action Plan on Business and Human Rights (NAP) to enforce compliance with human rights in global supply and value chains. The German Sustainability Code (DNK) offers the opportunity to comply with the fourth core element of the NAP – reporting – by submitting a DNK declaration.

Companies that want to disclose their commitment to protecting human rights in detail can select in the database that they want to use the DNK including the NAP reporting points. The supplement is then displayed and reviewed for formal completeness by the German Sustainability Code Office as part of its critical review process. Responsibility for the content remains with the reporting organisations.

The NAP Helpdesk of the Agency for Economic & Development provides free advice on the requirements of the National Action Plan, NAP monitoring and international projects in the field of sustainability in general. You can find FAQs about the National Action Plan on the NAP Helpdesk website.

The CSR Directive Implementation Act (CSR-RUG) requires certain companies to provide non-financial reporting in accordance with specific guidelines. The DNK can be used to prepare a non-financial report in accordance with the CSR-RUG. This requires some additional information, which is indicated when preparing the DNK declaration.

It is possible to supplement the DNK declaration retrospectively. However, we only recommend doing so if it is urgently necessary, e.g. in the case of important key figures that were not yet available when the DNK declaration was submitted.

Numbers are important, but sustainable business practices depend above all on ethical conduct and a vision for the future. Among other things, the benefit lies in taking individual people seriously in their actions and not hiding one's own responsibility behind mountains of data.

The German Sustainability Code helps to maintain credibility and access to markets, but also to continuously develop innovation and new thinking in companies while incorporating proven principles. With your declaration to the DNK, you demonstrate that you can report beyond your immediate company boundaries, including your supply chains. As a supplier, you can use the DNK to showcase your sustainability performance and thus score points when establishing new supply relationships.

You can also use the DNK to evaluate the economic performance of your company more comprehensively, which you would traditionally demonstrate with an annual report and numerous financial indicators. Show that your company is positioned for the long term to realise opportunities and is aware of the risks associated with sustainability issues. Consumers, politicians and financial service providers are asking for this. The DNK helps to provide answers to these stakeholders.

The primary target groups that use the DNK declarations are:

  • the company's own management, to steer sustainability within the company and to analyse and manage opportunities and risks;
  • the company's own and future employees who want to work for a company that demonstrates comprehensive responsibility;
  • customers and suppliers who value sustainability in the value chain;
  • political decision-makers who want to gain an impression of sustainable business practices;
  • and financial market players, to enable them to better assess the opportunities and risks of capital investments and loans.

Large companies can use the DNK to provide their partners in the supply chain with a simple tool that meets the sustainability requirements of their customers.

Non-governmental organisations and academia are also likely to be potential users. As the economy makes greater use of the DNK and the number of DNK declarations increases, the interest of the target groups will also grow.

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