VSME/VS and the value chain: the value chain cap and responsible purchasing

Q: Can a customer require more data from me than VSME/VS?

The Omnibus framework provides for the opposite: the value chain cap establishes that partners with 1,000 employees or fewer cannot be asked for more than the content of the voluntary standard. This cap only takes full effect after transposition of the directive, due by 19 March 2027 at the latest. An exception remains for information commonly shared in the sector.

Q: Is the value chain cap already in force?

Not fully, on 8 November 2026. The Omnibus I Directive (EU) 2026/470 that establishes it entered into force on 18 March 2026, but its concrete effect depends on national transposition (by 19 March 2027 at the latest) and the cap set by Delegated Regulation (EU) 2026/1560, in force since 24 September 2026, applies only to financial years beginning on or after 1 January 2027.

Most SMEs do not discover the VSME/VS standard out of regulatory curiosity, but because a customer, a bank or a public buyer asks them for sustainability data. It is this top-down pressure – what is known as a pull dynamic – that is the real driver of demand. The good news: the European framework does not merely open the floodgates of ESG questionnaires; it also tries to cap them. This cap has a name: the value chain cap. This page explains why large groups approach you, what this mechanism changes – with all the caution its status on 8 November 2026 calls for – and how to respond to a request without being pushed beyond the scope.

Why large groups ask their suppliers for ESG data

A company subject to the CSRD does not only report on its own activities: it must also document the impacts, risks and dependencies of its value chain, both upstream and downstream. In practice, a large contracting customer needs data on its suppliers’ energy, emissions, working conditions or ethics to build its own sustainability report. Hence the avalanche of questionnaires landing in SMEs’ inboxes.

This shifting of the burden is sometimes called “indirect CSRD”: the SME is not legally subject to the CSRD, but it feels the knock-on effect through its contracts. With the Omnibus I Directive, this phenomenon is growing in scale. The scope of the CSRD has been narrowed to companies exceeding two cumulative thresholds: more than 1,000 employees and more than €450 million in net turnover (for financial years beginning on or after 1 January 2027). Many companies are therefore leaving the mandatory scope… while themselves remaining suppliers to larger companies. The result: the population likely to receive – and to issue – standardised ESG requests is widening, and the need for a common language is becoming pressing. VSME/VS sets out to be precisely that language.

The value chain cap: a ceiling on requests made to partners with 1,000 employees or fewer

Faced with the risk of burying SMEs under heterogeneous questionnaires, the EU legislator introduced a safeguard: the value chain cap. The idea is simple to state: a large company cannot require a partner with 1,000 employees or fewer to provide more sustainability information than the voluntary standard for SMEs provides for. Beyond this cap, the partner may refuse.

The value chain cap: the most a contracting customer can request

Legal basis (Omnibus I, Articles 19a/29a of the Accounting Directive 2013/34/EU)

The mechanism is established by the Omnibus I Directive – Directive (EU) 2026/470 of 24 February 2026, which entered into force on 18 March 2026. According to the proposal that preceded it (COM(2025) 81), the cap is set out in Articles 19a and 29a of Accounting Directive 2013/34/EU, the very articles that govern sustainability reporting. Two effects are expected: protected companies may refuse any request exceeding the cap, and contractual clauses purporting to impose more would be unenforceable. The exact wording of the articles must be checked against the published text before any verbatim quotation; here we stay at the level of principle.

The content of the cap refers to the voluntary standard (effective after transposition, 19/03/2027)

What exactly does this cap contain? The text adopted on 3 July 2026 and published in the Official Journal of the EU on 21 September 2026 finally provides a precise answer: its Article 3(2) provides that the cap ‘comprises only the data points referred to in Annex II’. It is therefore not the whole standard, contrary to what might have been assumed before its publication. This annex retains extracts from the Basic Module (B1, B3, B6 to B10 – B2, B4, B5 and B11 are absent) and only four disclosures from the Comprehensive Module (C1, C5, C6 and C7). It also distinguishes two lists: a lighter one for undertakings with 10 employees or fewer, and another for larger ones. In practical terms, the scope that can be enforced against an SME is narrower than the standard itself – which is good news for SMEs. This standard has been in force since 24 September 2026 (Delegated Regulation (EU) 2026/1560, adopted under reference C(2026) 5011), but its Article 3, which sets the cap, applies only to financial years beginning on or after 1 January 2027. The cap itself only takes concrete effect once the Omnibus Directive has been transposed into national law, i.e. by 19 March 2027 at the latest. In other words: the principle is established, but on 8 November 2026 a contracting customer cannot yet be met with a refusal based on a definitively applicable text. Caution is therefore needed regarding the actual date of application.

The “information commonly shared in the sector” exception

The cap is not absolute. A carve-out applies to information commonly shared within the sector concerned: a contracting customer will still be able to request data that is customary in its industry, even if it goes beyond the strict content of the standard. This exception, whose final wording remains to be checked against the published text, avoids freezing legitimate sector practices – but it is also the main grey area of the framework. In practice, it invites every SME to distinguish what reflects established practice in its industry from what is merely an excessive, isolated demand.

Legal status – as of 8 November 2026. The value chain cap is provided for by the Omnibus I Directive (EU) 2026/470, which entered into force on 18 March 2026, but its concrete effect depends on national transposition, due by 19 March 2027 at the latest. The voluntary standard it refers to, adopted by delegated act on 3 July 2026, was published in the Official Journal of the European Union on 21 September 2026 (Delegated Regulation (EU) 2026/1560) and has been in force since 24 September 2026; the cap it sets applies to financial years beginning on or after 1 January 2027. VSME/VS, an EFRAG standard, had been endorsed by Recommendation (EU) 2025/1710 of 30 July 2025, a soft-law instrument which ceased to produce legal effects on 24 September 2026. Every statement above is dated and subject to change: see our regulatory watch.

Answering a customer ESG questionnaire with VSME/VS

In practice, how should you handle a customer’s request? The approach comes down to three steps.

Prepare. Rather than reacting questionnaire by questionnaire, build a data foundation once and for all following the VSME/VS Basic Module (disclosures B1 to B11: basis for preparation, energy and emissions, workforce, ethics…). Our guide applying VSME/VS in an SME details this data collection step by step. The same foundation then serves several stakeholders.
Provide. When faced with a request, provide your VSME/VS report as the reference answer. A structured, dated and sourced report often makes a better impression than a series of ticked boxes, and it positions you as a supplier in command of the subject. For a firm supporting its clients, this deliverable becomes a structured engagement in its own right.
Politely decline what is out of scope. When a question clearly goes beyond the content of the standard – and does not reflect common practice in your sector – you can courteously refer back to the scope of voluntary reporting. The value chain cap provides a principled basis for this refusal; pending its full application, it already offers a strong negotiating argument.

The advantage of this approach: the same report goes to several recipients – a customer, a bank, a buyer – without being rebuilt each time.

One report for several stakeholders

For a detailed use case, see our article My customer has sent me an ESG questionnaire: answering with VSME/VS.

VSME/VS in tenders and public procurement

The value chain is not limited to private commercial relationships. More and more tenders – private and public alike – include sustainability criteria: energy consumption, greenhouse gas emissions, social policy, business ethics. Having an up-to-date VSME/VS report makes it possible to meet these requirements faster and consistently, where many competitors improvise.

Two methodological caveats apply. First, a public buyer remains in control of its criteria: VSME/VS makes answering easier, but it does not replace the answer and confers no automatic right. Second, the value chain cap governs contractual requests between partners covered by the framework; its reach in public procurement must be assessed case by case, as the texts become clearer. VSME/VS is therefore a tool for competitiveness and anticipation here, to be presented as such rather than as a passport to success.

Decision tree: should I respond to this request?

Not every request calls for the same response. Three outcomes are possible: answer directly (the data is simple and you already have it), provide your VSME/VS report (the request falls within the scope of the standard), or politely decline the out-of-scope part (the requirement exceeds the cap without reflecting common sector practice). The diagram below summarises this process.

Should I respond to this request?

First, a preliminary question: are you even within the relevant scope? Our page Does VSME/VS apply to me? helps you decide in a few minutes.

FAQ

Can a customer require more data from me than VSME/VS?

The Omnibus framework provides for exactly the opposite: the value chain cap establishes that partners with 1,000 employees or fewer cannot be asked for more than the content of the voluntary standard. However, this cap only takes full effect after transposition of the directive, due by 19 March 2027 at the latest. Until then, it is above all an argument of principle and a negotiating point. An exception remains for information commonly shared in your sector.

Is the value chain cap already in force?

No, not fully, on 8 November 2026. The Omnibus I Directive (EU) 2026/470 that establishes it entered into force on 18 March 2026, but its concrete effect depends on national transposition (by 19 March 2027 at the latest) and the cap set by Delegated Regulation (EU) 2026/1560, in force since 24 September 2026, applies only to financial years beginning on or after 1 January 2027. The mechanism therefore exists in law without yet being fully operational.

Do I have to answer every ESG questionnaire I receive?

You are under no legal obligation to do so: VSME/VS is a voluntary framework. Commercially, however, answering may be a condition for a contract, financing or market access. The right approach is to prepare a reusable data foundation, provide your report as the reference answer, and courteously decline anything beyond the standard scope.

Is VSME/VS enough to respond to a contracting customer subject to the CSRD?

In the logic of the framework, yes: the voluntary standard for SMEs is designed precisely to provide large groups with the value chain data they need, in a harmonised format. That is the whole point of a common language. If a contracting customer asks for more, first check whether the information is genuinely customary in your sector before agreeing to go further.