VSME and the CSRD Value Chain Cap: What Large Companies Need to Know

If you are reporting under CSRD, you are probably asking the same question many large companies are asking right now:

Will VSME data be enough to cover my value chain data needs, or am I expected to ask for more?

With Omnibus I, the EU has now given a much clearer answer. For value chain partners with fewer than 1,000 employees VSME is positioned as the cap for what you should request for CSRD purposes.

That has important consequences for how you design questionnaires, follow up suppliers, and build your CSRD data model.

What changed with Omnibus

In February 2026, the final legal text amending the CSRD and the CSDDD was published as part of Omnibus. We have previously unpacked what the scope changes mean and how the negotiations evolved, including the final agreement reached on 9 December (read here).

One point deserves particular attention for large companies:

Voluntary reporting standards, play a much stronger role in how sustainability data is expected to flow through value chains.

In practice, this puts the VSME standard in a new position; not just as a voluntary reporting option for smaller companies, but as a reference point for what CSRD reporters can reasonably ask for.

VSME now serves two purposes:

1. A voluntary reporting route. Companies that fall outside CSRD, including companies with fewer than 1,000 employees, can use VSME to report on sustainability and compliance data in a structured, comparable way.
2. A cap on value chain data request.  More importantly, VSME acts as a cap for what CSRD reporting companies can request from companies with fewer than 1,000 employees in their value chain. This is often referred to as the value chain cap.

The rest of this article focuses on what that means in practice.

The value chain cap in practice

Without clear limits, value chain data requests tend to grow over time. Different internal teams send their own questionnaires, while customers ask suppliers for similar information in different formats. This leads to more follow‑ups, missed timelines, and growing frustration on both sides.

The value chain cap is intended to limit sustainability reporting requirements being pushed down the supply chain, often referred to as the “trickle-down-effect”, which particularly affects SMEs in the value chain. The expectation is clear: companies are expected to request only what is strictly necessary for CSRD reporting and to avoid excessive detail and customisation.

What this means for your CSRD reporting

Omnibus I also strengthens the position of SMEs and other out-of-scope companies.

When information is requested specifically for CSRD reporting, value chain partners can decline to provide information that goes beyond what is covered by the voluntary standard. In other words, they now have a clearer backing to push back on excessive requests.

At the same time, CSRD reporters can still meet their reporting obligations by limiting requests to VSME‑level information and addressing any remaining gaps through estimates, proxies, or internal assumptions. This shifts the focus from “collect everything” to “collect what is proportionate, and document how you fill the gaps”.

Are you ready to turn VSME into a practical value chain data tool?

For large companies, the key question now is no longer whether VSME matters, but whether your current value chain data setup is aligned with it. Knowing that VSME is the cap is one thing. Applying it consistently across procurement, sustainability, and reporting is another.

In practice, VSME can function as a shared baseline for suppliers requests, helping to standardise questionnaires, reduce follow‑ups and ad hoc data requests, and provide a defensible reference point anchored in a recognised standard. However, simply adding VSME questions to supplier questionnaires does not, on its own, address the trickle‑down effect. To fully unlock its value, reporting companies need to be able to receive VSME report in a structured, digital format that enables analysis and supports sustainability reporting and value chain risk assessments. When this is in place, the voluntary standard can generally cover the information needed from the value chain for CSRD purposes.

A few practical checks:

1. Are your supplier data requests aligned with the VSME?
2. Can you receive and analyze VSME reports from your value chain?
3. Can you clearly explain why each data point is needed for CSRD?
4. Do you know where you rely on estimates or proxies – and why?

If not, now is the time to adjust.

Want a one-pager?

If you want a one-page overview of how to prepare value chain data requests under the CSRD value chain cap, and what the VSME provides for CSRD reporting, you can download our one-pager here:

How can we help

If you are unsure where to start, especially when it comes to using VSME reports in value chain data collection, reach out to us or book a demo to see how this can work in practice.

11 March 2026