The Value Chain Cap: What It Means for VSME Reporters

A legal ceiling on what your customers can ask

For two years, the pattern has been the same. A large customer comes into scope of CSRD, its reporting team works out that most of its footprint sits in the value chain, and a questionnaire lands with every supplier on the list. Each one is different. Some ask for a handful of figures; others run to two hundred questions, many of them lifted straight from the full ESRS.

The Omnibus I Directive put a limit on that. It is called the value chain cap, and as of this week it has real content: the Commission’s voluntary sustainability reporting standard, Delegated Regulation (EU) 2026/1560, was published in the Official Journal on 21 September 2026 and is available for use from 24 September. That standard is based on the VSME, and it now does two jobs at once.

What the cap actually says

A company that reports under CSRD may not require a company in its value chain with 1,000 employees or fewer to provide more sustainability information than the voluntary standard sets out. The practical details:

• Who is protected. Any undertaking with an average of 1,000 employees or fewer over the preceding financial year. That is not only SMEs in the formal sense; it covers most mid-sized suppliers as well.
• Where the ceiling sits. The disclosures the standard marks as “necessary”. Items marked voluntary, necessary-if-applicable or sector-specific are above the cap. Micro-undertakings with ten employees or fewer get additional relief: several environmental disclosures that are necessary for larger companies are voluntary for them.
• When it bites. Requests relating to financial years beginning on or after 1 January 2027 — in other words, the data your customers will be collecting from early next year.
• What it does not cover. Information your customer needs to comply with other EU or national law, such as the Deforestation Regulation, sits outside the cap.

Customers can still ask for more. What changes is that they can no longer make it a requirement, and requests beyond the cap are expected to be flagged as such so that the supplier knows it is entitled to decline.

The cap is a ceiling, not an obligation

It is worth being precise about what this does not do. The voluntary standard remains voluntary. Nothing in the cap obliges a supplier to report, to use the standard, or to seek assurance on what it provides. And nothing obliges a customer to keep buying from a supplier who provides nothing at all.

That second point matters more than it first appears. A CSRD reporter that cannot obtain value chain data is allowed, for a transitional period, to explain the gap and fill it with estimates. Those estimates are typically sector averages, and sector averages are rarely flattering to a supplier that has actually invested in efficiency. A supplier that declines to answer is not removed from its customer’s Scope 3 figure. It is simply represented by someone else’s assumption.

Why VSME just became the default answer

Until now, preparing a VSME report was a reasonable choice among several. The cap changes the arithmetic. Because the voluntary standard defines the maximum a customer can require, it also defines, in practice, the dataset every customer is going to converge on. Buyers have no reason to design a bespoke questionnaire they cannot enforce.

For a supplier, that turns a moving target into a fixed one:

• The Basic module — energy, greenhouse gas emissions, pollution, biodiversity, water, waste, workforce, health and safety, pay, training and anti-corruption — covers the core of what sits under the cap.
• The Comprehensive module adds strategy, transition planning, human rights and similar context. It builds on Basic and cannot be applied on its own.
• One dataset, many recipients. A report prepared against the standard answers every CSRD customer at once, in a form they already expect, and is also the structure banks increasingly use for their own climate disclosures.

What to do before January

The cap applies to the 2027 financial year, which means the questionnaires that test it will arrive in the first half of next year. The suppliers who handle it best will have done four things by then:

• Confirm the headcount. Check your average employee number for the preceding financial year. The protection depends on it, and so does whether the micro-undertaking relief applies.
• Map existing questionnaires against the standard. Take the customer requests you answered this year and mark each question as inside or above the cap. Most suppliers find the overlap is large and the remainder is small.
• Decide deliberately what you answer above the cap. Declining is now a legitimate option. For a strategically important customer, answering a few extra questions may still be the right commercial call. The point is that it becomes a decision rather than a reflex.
• Build the Basic module once, with sources attached. Every figure should trace back to an invoice, meter reading or payroll export, so that next year is a refresh and not a restart.

From defensive right to commercial position

The value chain cap is usually described as protection for small companies, and it is. But the more useful way to read it is as standardisation. For the first time, a supplier knows exactly which questions its customers are entitled to ask, and can prepare one complete, evidenced answer instead of fifty partial ones.

That is the ground we covered in The VSME Survival Guide, and the cap makes it firmer.

How Planmark helps

The cap tells you what the answer has to contain. Producing that answer, and producing it again next year, is still work. Planmark is built to take most of that work away:

• The VSME structure is already there. Data is collected against the Basic and Comprehensive modules, with guidance in every field in English, Finnish and Swedish, so you are working to the same standard that defines the cap rather than to a blank spreadsheet.
• Figures come from documents you already have. Upload electricity and heating invoices, meter readings or supplier documents, and AI extracts the activity data and matches it to the right emission factor.
• Every number keeps its source. Version history and an audit trail sit behind each figure, so an answer still holds when a customer comes back with a follow-up question.
• Ownership is explicit. Each disclosure can be assigned to the person who holds the data, with comments resolved in context instead of across email threads.
• One report for every customer. The finished VSME report can be shared as a visual report and translated, so the same evidenced answer goes to every customer that asks.
• It stays current. As the voluntary standard and its guidance evolve, Planmark tracks the changes for you.

The same platform works from the other side of the relationship. If you report under CSRD yourself, Planmark’s value chain tools send structured data requests to suppliers and chase what has not come back — which makes it straightforward to keep those requests inside the cap.

See how it works on our VSME reporting page, or book a demo and we will walk through your own customer questionnaires against the standard.