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The value chain cap explained

How the value chain cap protects companies with up to 1,000 employees from excessive sustainability questionnaires from 2027, and how to reply when a request goes further.

Last updated: 2026-10-12 · 2 min read

If you supply a large company, you may already receive long sustainability questionnaires. From financial year 2027, EU law limits what a CSRD-reporting customer can require from you for its sustainability report.

Who is protected

Companies in a reporting company's value chain with no more than 1,000 employees on average in the previous financial year. You can self-declare your size, and the customer may rely on that declaration unless it is clearly wrong.

What the cap means

  • For CSRD reporting purposes, a customer may not require information beyond the datapoints that the Voluntary Standard lists for the value chain cap.
  • If a customer asks for more, it should say which questions go beyond the cap and tell you that you can decline them.
  • You may still choose to share more information.
  • In its first three years of reporting, a customer that cannot get all the data it wants may explain the gap and use estimates.

What the cap does not cover

  • Requests made under other laws, for example the EU Deforestation Regulation or due-diligence rules.
  • Ordinary commercial negotiations: a customer can still prefer suppliers with better data.
  • Banks' own risk assessments are a separate channel. The European Commission encourages banks to base their SME requests on the VS "as far as possible".

A practical reply strategy

  1. Prepare your Basic Module report once.
  2. When a questionnaire arrives, answer the overlapping questions by pointing to your VS report.
  3. For questions beyond the cap, reply politely that you report under the Voluntary Standard and ask the customer to confirm the purpose and legal basis of the extra request.

The VS Supplier Kit includes ready-to-send reply letters in English and Romanian for these situations.

Timing note: the cap was introduced by Directive (EU) 2026/470 (Omnibus I). EU member states must bring the related provisions into national law, and secondary sources report a deadline of 19 March 2027. Check your country's status before relying on the cap in a dispute.

Sources: Delegated Regulation (EU) 2026/1560; Directive (EU) 2026/470; Commission press release IP/25/1843 (30 July 2025); Generation Impact and Dcycle analyses (secondary). General information, not legal advice.