ACCA welcomes the opportunity to comment on the draft Voluntary ESRS for Non-Listed Small and Medium Sized Enterprises (VSME). We have also fed into the responses submitted by EFAA and Accountancy Europe and agree with the stances taken; this written submission sets out ACCA’s position on the standard, given our other joint submissions. We would like to emphasise the role of the participants in the field test and that their feedback will be most critical in the finalisation of the standard.
ACCA broadly support the objectives of the VSME. The European Green Deal and related policies have resulted in a raft of new legislation, that has the capacity to create significant compliance and cost burdens, particularly for small businesses. The operational burden has the risk of also extending to the provision of sustainability-related information. This burden, together with ongoing geopolitical tensions and inflation, create unprecedented challenges for SMEs. For the green and digital transitions to be delivered successfully, EU regulation applying to SMEs needs to be proportionate and limited to what is necessary. This includes the future EU voluntary reporting standard for non-listed SMEs (VSME).
The VSME generally delivers on meeting these challenges in an accessible and reasonable format subject to the following dependencies. EFRAG need to continually recognise that the success of the VSME depends on market acceptance by lenders, investors, and other relevant business stakeholders, which will require awareness raising of VSME. In tandem SMEs will need to undertake significant upskilling, supported by additional guidance, Q&As. A best practice example of this is the interoperability mapping between the ISSB and ESFRAG ESRS which could be extended to cover the ESRS for Listed Small and Medium Sized Enterprises (LSME) and VSME standards. ACCA has a considerable amount of educational materials both published and in the pipeline. Our sustainability reporting course is due to launch and complements our diploma in sustainability that is currently under development and which we hope to launch later in 2024. Other materials include our Accounting for a better world - our agenda for action | ACCA Global
To read the response in full, please download the consultation response document on this page.