Template for hotels

VSME template for hotels: what to report and where to find the data

The EU voluntary sustainability standard for SMEs (VSME) has a Basic Module of 11 disclosures. This page turns them into a checklist for a hotel: what each one asks for and which document already holds the data.

Updated October 2026

Before you start

The VSME was published by EFRAG in December 2024 and recommended by the European Commission on 30 July 2025 (Recommendation (EU) 2025/1710). It is voluntary.

Use one full calendar or financial year. Collect bills for every site you include, and keep a note of any number you estimate and how.

If a disclosure does not apply to your hotel, you can leave it out. Readers will assume it does not apply.

The 11 Basic Module disclosures

Code	Disclosure	What a hotel reports	Where to find the data
B1	Basis for preparation	Which module you use (Basic, or Basic + Comprehensive), legal form, NACE code (55.10 for hotels), turnover, balance sheet total, number of employees, country, the sites covered and any sustainability certificates or labels.	Annual accounts, company registry, any eco-label certificate.
B2	Practices, policies and future initiatives	What you already do or plan on climate, pollution, water, biodiversity, resources, your staff, the local community and business conduct, and whether there is a written policy and a target for each.	Your own procedures, staff handbook, supplier rules.
B3	Energy and greenhouse gas emissions	Total energy use in MWh, split into renewable and non-renewable electricity and fuels; estimated Scope 1 and location-based Scope 2 emissions in tonnes of CO2-equivalent; emissions divided by turnover.	Electricity, gas, diesel and LPG bills for the full year; laundry and boiler fuel; company vehicles.
B4	Pollution of air, water and soil	Pollutants you emit, only if you already have to report them under law or in an environmental management system.	Permits and environmental reports, if any.
B5	Biodiversity	Number and area of your sites in or near biodiversity-sensitive areas (for example Natura 2000 sites).	Your site location checked against the Natura 2000 map.
B6	Water	Total water withdrawal, with the share taken at sites in areas of high water stress shown separately.	Water bills and meter readings, including any well or borehole.
B7	Resource use, circular economy and waste	How you apply circular-economy principles; total waste per year, split into non-hazardous and hazardous, and how much goes to recycling or reuse.	Waste collector invoices and certificates; kitchen and housekeeping records.
B8	Workforce: general characteristics	Employees by type of contract, gender and country, as headcount or full-time equivalents; staff turnover rate if you have 50 or more employees.	Payroll and contracts, including seasonal staff.
B9	Workforce: health and safety	Number and rate of recordable work-related accidents and number of fatalities.	Accident register and your occupational risk prevention service.
B10	Workforce: pay, collective bargaining and training	Whether pay meets the applicable minimum wage, the gender pay gap, the share of employees covered by collective agreements and average training hours per employee by gender.	Payroll, the hospitality collective agreement, training records.
B11	Convictions and fines for corruption and bribery	Number of convictions and total fines for breaking anti-corruption and anti-bribery laws.	Legal records; usually zero.

And the Comprehensive Module?

The Comprehensive Module adds nine disclosures (C1 to C9), such as your business strategy, climate targets, climate risks and human rights policies. Most hotels start with the Basic Module and add the Comprehensive one when a bank or a large client asks for it.

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Quick answers

Is the VSME mandatory for hotels?

No. It is a voluntary standard that the European Commission recommends to small and medium-sized companies.

How long does the Basic Module take?

Most of the work is collecting a year of bills and payroll figures. With those at hand, a small hotel can fill in the 11 disclosures in a few days.

Which emissions do I need to estimate?

Scope 1 (fuel you burn on site and in company vehicles) and location-based Scope 2 (the electricity you buy). Scope 3, from suppliers and guests' travel, is not required in the Basic Module.

Sources: Commission Recommendation (EU) 2025/1710 of 30 July 2025, Annex I (VSME); EFRAG interactive VSME.