The value-chain cap: what information may CSRD companies request from suppliers?
Last updated: · steward-ship
Under the value-chain cap introduced by Omnibus I, a company in CSRD scope may not request information beyond the Voluntary Standard (VS) from value-chain partners with up to 1,000 employees, and those partners may decline to answer. The VS, Commission Delegated Regulation C(2026) 5011 (published as 2026/1560), entered into force on 24 September 2026.
Who is protected?
Value-chain partners with 1,000 employees or fewer. Treating a supplier of unknown size as protected is the prudent approach.
What may be requested?
- Core information within the VS, e.g. energy consumption and Scope 1–2 GHG emissions
- Requests beyond the VS (e.g. product carbon footprints) only from partners with more than 1,000 employees
What it means for Scope 3
A supplier's Scope 1–2 emissions and net turnover can be allocated to the buyer by spend share using the GHG Protocol hybrid method, which gives better data quality than spend-based estimates.
What does do?
's supplier data requests enforce the cap in code: protected suppliers cannot be sent non-VS questions, the form states the right to decline, and suppliers answer through a link without an account.
Sources
ESRS 2026 · TSRS · Voluntary Standard (VS)