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

  1. Directive (EU) 2026/470 (Omnibus I)
  2. Commission Delegated Regulation C(2026) 5011 — Voluntary Standard
  3. Delegated Regulation (EU) 2026/1560 (Official Journal)
  4. GHG Protocol Corporate Standard
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ESRS 2026 · TSRS · Voluntary Standard (VS)