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AdoptedGuidanceMEDIUM ImpactCSRDESRSEU TaxonomyGreen ClaimsAI-Enriched

AFM Guidance on POG Requires Robust Product Sustainability Data

December 10, 2025
AFM - CSRD Implementation

AI-Powered GS1 Impact Intelligence

Analysis generated by ISA's AI to help you understand how this news affects GS1 standards and your operations.

PRODUCT MASTER DATAESG REPORTINGIDENTIFICATIONRETAILFOODGENERAL

Impact Analysis

The core challenge is ensuring that sustainability data (e.g., carbon footprint, circularity, ethical sourcing) linked to a product's GTIN is accurate and accessible. GDSN is essential for standardizing and sharing these specific product master data attributes with downstream partners, including financial institutions assessing investment suitability. Consistent use of GS1 identifiers (GTIN, GLN) ensures that the sustainability data reported to the AFM is linked to the correct physical product and responsible party.

Recommended Actions

  • Review and update GDSN product master data templates to include mandatory sustainability attributes required by ESRS E1-E5.
  • Ensure all sustainability claims linked to the GTIN are verifiable and supported by auditable data, preparing for Green Claims Directive requirements.
  • Collaborate with supply chain partners to standardize the exchange of sustainability data using GS1 standards before sharing with financial intermediaries or consumers.
Regulatory Event Context
Complete

EFRAG Expands VSME Digital Template and XBRL Taxonomy Language Support

EFRAG updated the Voluntary Sustainability Reporting Standard for SMEs (VSME) Digital Template and XBRL Taxonomy by adding four new languages: Danish, French, German, and Italian. This expansion brings the total supported languages to nine, significantly improving accessibility for SMEs across the EU preparing for sustainability reporting. The update also includes a technical FAQ to clarify common user questions regarding the template and taxonomy.

GuidanceGuidanceMedium Risk2025-Q4

Affected Regulations

CSRDESRSEU Taxonomy

Delta Analysis

Previous Assumption

The market assumed that EFRAG's initial focus for digital reporting tools (like the VSME template) would prioritize English and major EU languages, potentially leaving smaller or non-core language regions with higher translation burdens initially. SMEs in non-English speaking countries faced potential delays or increased costs in adopting the voluntary standard due to language barriers in the reporting tools.

New Information

The VSME Digital Template and XBRL Taxonomy now support nine languages, including the newly added Danish, French, German, and Italian. EFRAG utilized AI for initial translation drafts, which were subsequently reviewed and corrected by National Standard Setters, indicating a robust, scalable mechanism for future language additions. This rapid expansion signals EFRAG's commitment to broad EU accessibility.

What Changed

The ease of access and usability of the VSME reporting tools for SMEs across the EU has dramatically improved due to the immediate availability of four major European languages. This lowers the technical barrier for sustainability data submission for a large segment of the EU market, accelerating the expected timeline for widespread VSME adoption and data collection by supply chain partners.

What Did Not Change

The fundamental requirements and structure of the VSME standard itself remain unchanged; only the accessibility tools (template and taxonomy language display) were updated. The underlying need for robust product and location master data management, potentially leveraging standards like GS1, to populate the required sustainability metrics is still necessary.

Decision Impact

Stakeholders relying on SME sustainability data (e.g., large companies under CSRD) should accelerate their readiness planning, as widespread VSME adoption is now more likely and imminent. Technology vendors must ensure their reporting solutions integrate seamlessly with the multi-lingual XBRL taxonomy. Companies should prioritize ensuring their internal data systems (including GS1 identifiers for traceability) can feed data into the VSME structure regardless of the language interface used by the reporting entity.

Completeness Score
100%
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