The European Commission has published a Q&A on the new value chain cap agreed by the co-legislators in the Omnibus I Directive, clarifying how it will limit the sustainability information that companies subject to the Corporate Sustainability Reporting Directive can require from companies in their value chain. For CSRD reporting purposes, those reporting companies cannot require value chain companies with 1000 employees or fewer to provide more information than is covered by the Commission's voluntary sustainability reporting standard, which has been published for public feedback. The Commission explains that the draft voluntary standard contains a basic module and a comprehensive module, with disclosures classified as necessary, necessary if applicable, voluntary, or consideration when reporting sector information. Under the draft delegated act, only disclosures marked as necessary fall within the value chain cap, and this applies across both modules. Some disclosures that are necessary for companies with 11 to 1000 employees are treated as voluntary for companies with 10 employees or fewer, giving the smallest companies a lower cap. The cap applies only to CSRD reporting obligations and does not restrict information requests made for other purposes. The Q&A also states that CSRD companies may still request information above the cap, but they must clearly identify which information exceeds the cap and inform the value chain company that it has a statutory right to decline. It also clarifies that non-CSRD companies are not required to use the voluntary standard or to provide sustainability information, and that companies subject to the CSRD should request only the information they need rather than the full amount permitted under the cap.
European Commission 2026-05-06
European Commission explains CSRD value chain cap tied to voluntary sustainability reporting standard for companies with up to 1000 employees
The European Commission has issued a Q&A on the new value chain cap in the Omnibus I Directive, clarifying limits on sustainability data CSRD reporters may request from value chain companies. For CSRD reporting, entities with 1,000 or fewer employees cannot be asked for more information than in the draft voluntary sustainability reporting standard, and only disclosures marked “necessary” count toward the cap, with a lower cap for entities with 10 or fewer employees. The cap applies only to CSRD reporting; non-CSRD companies are not required to use the voluntary standard or provide information. CSRD reporters may seek information beyond the cap only if they label it as such and acknowledge the counterparty’s right to refuse.