What does sustainability mean for a Swiss SME?
On July 3, 2026, the EU Commission adopted the voluntary sustainability standard as a delegated act. It looks harmless – „voluntary.» In reality, it decides which ESG data an SME in the supply chain still has to provide. An analysis.
Those who have followed European ESG regulation since the first CSRD consultation have learned to distrust announcements and focus on the mechanics. July 3, 2026, was one of those days when the mechanics were more important than the headline. The EU Commission, with its delegated act C(2026) 5011 Final adopts the voluntary sustainability standard for companies outside the scope of CSRD – the binding version of what has so far been circulating the market as the VSME recommendation. The abbreviation „VS» (Voluntary Standard) has quickly become established in professional discussions. The real news is not in the title: a „voluntary» standard becomes the binding upper limit for everything that large customers and banks may demand from smaller suppliers.
That sounds like a technical detail. It's the reason why the VS will become more relevant for the mid-market in the next 18 months than the CSRD itself.
1. Where the CSRD ends – and what Omnibus has changed about it
The Corporate Sustainability Reporting Directive (CSRD) its original version was designed for around 50,000 companies in the EU. It requires an audited sustainability report according to the ESRS (European Sustainability Reporting Standards), including dual materiality analysis and external audit. This is challenging but manageable for a large, capital-market-oriented company. For the traditional medium-sized business, it was too much from the start.
This is exactly where the Omnibus I Package The Commission proposed it on February 26, 2025; the corresponding amending directive was finally adopted in early 2026 and entered into force in the spring of 2026. Three interventions are crucial for small and medium-sized enterprises:
First, the scope of application. The CSRD obligation now only applies to companies with more than 1,000 employees and about 450 million EUR revenue. This dramatically reduces the number of companies subject to reporting requirements—estimates suggest a reduction of about 80 %. The majority of small and medium-sized enterprises are thus formally exempt from this direct obligation.
Secondly, the streamlining of the ESRS. The revised standards reduce the number of data points from approximately 1.073 to approximately 320 (if material) – a decrease of more than 70 %, and for mandatory data points, more than 60 %. However, the dual materiality framework—ESRS 1 and 2 as the mandatory framework and E1 (climate) as the data backbone—remains in place. The CSRD will thus become simpler, but not substantially different.
Third – and this is the real lever – the „Value Chain Cap.». A company subject to CSRD may require business partners to fewer than 1,000 employees No more sustainability information beyond the voluntary standard will be requested. A recommendation becomes a legal cap. The VS is no longer just an offer for SMEs - it is the legal limit of what can be demanded from them.
Critically evaluated
The cap protects against mandatory data requests beyond the VS – not against voluntary ones. Large customers can still request more, and many SMEs will supply for commercial reasons. Banks also operate partly outside the value chain logic due to their own regulatory requirements. „All requirements met» is therefore more precise than „all standardized requirements met.».
CSRD Obligation Ends – VS Standard Begins
Mandatory
CSRD
1,000+ employees AND
450 million EUR in revenue
- Full ESRS (~320 DP, if significant)
- Double materiality analysis
- External audit requirement (Assurance)
VOLUNTARY · CAPPED
VS-Standard (Based on: VSME)
Less than 1,000 employees
outside the scope of CSRD obligations
- Base Module B1–B11 (Core KPIs)
- Comprehensive C1–C9 (on request)
- No mandatory materiality, no audit obligation
VALUE CHAIN CAP (Omnibus I)
A company subject to CSRD may not require SME suppliers to do anything beyond the EU standard (European Sustainability Reporting Standards).
Fig. 1 — Delimitation CSRD ↔ VS Standard. The Value Chain Cap makes the voluntary standard a binding upper limit for data requests along the supply chain.
2. From VSME to VS: The Development of a „Voluntary» Standard with Teeth
The VS doesn't fall from the sky. Its history explains why it is so effective. EFRAG had the VSME – the „Voluntary Sustainability Reporting Standard for non-listed SMEs» – in December 2024 Handed over to the Commission. It was the pragmatic answer to a real problem: SMEs were inundated by customers and banks with a proliferation of individual ESG questionnaires. The VSME was intended to curb this proliferation by one replace standardized information.
In the July 2025 did the Commission take over the VSME as Recommendation. An recommendation in EU law is „soft law» — non-binding. That is precisely what changed with Omnibus. The VSME went from being good advice to a legally enshrined reference point for the Value Chain Cap. And with the delegated act of July 3, 2026 Does this version now have binding legal force as a delegated regulation – no longer advice, but applicable law.
The content structure of the VSME remains largely the same: a Foundation Module (B1–B11) with the core key figures most frequently requested by value chain partners – including Scope 1 and 2 GHG emissions, key figures on your own workforce, energy, and anti-corruption. Building on this, a Comprehensive Module (C1–C9) for the additional information that banks, investors, and major clients typically require on top of that. The basic module is a prerequisite for the comprehensive module.
The VS is not a „new» standard, but rather the VSME with legal teeth. Substantially, the disclosures hardly change; what changes is the legal status (recommendation → delegated regulation) and the function (template → statutory data limit). Those who understand this will position themselves correctly in the market sooner.
The essential differences: VSME (2024/25) → VS (2026)
| Dimension | ESRS (EFRAG Recommendation) | VS-Standard (Delegated Act) |
|---|---|---|
| Legal status | Commission Recommendation (soft law), July 30, 2025 | Delegated Regulation – binding EU law, C(2026) 5011 final of 3.7.2026 |
| Commitment | Non-binding, purely voluntary application | Voluntary for the SME – but binding as a ceiling for applicants |
| Function in the supply chain | Standardized Response Template to Prevent Questionnaire Proliferation | Statutory „Value Chain Cap»: defines the maximum number of permissible requests |
| Protection for SMEs | None – customers could demand as much as they wanted | Yes – legal right to decline requests beyond the VS |
| Module structure | Base B1–B11 + Comprehensive C1–C9 | Largely adopted (content-wise VSME-based) |
| Double materiality | Not mandatory | Not mandatory (consciously low-threshold) |
| External Audit | No obligation to assure | No obligation to assure |
| Relationship to CSRD/ESRS | Consciously „lighter» than ESRS | Reference point that ESRS reporting entities must not exceed towards SMEs |
| Status & Schedule | Handover 12/2024, Recommendation 07/2025 | Farewell 07/03/2026; EP/Council review phase (up to 4 months); application from FY 2027, voluntary from FY 2026 |
The exact number of data points for the VS varies depending on the counting method and the final annex of the legal act; circulating figures range from around 46 frequently requested basic data points to approximately 140 data points across both modules. The final version should be compared with the published annex.
3. Why the VS is becoming the de facto data exchange standard
Regulation rarely takes effect where it formally begins, but rather where market behavior changes. The VS strikes a chord because it serves three interests simultaneously. For the Conglomerate it solves a compliance problem: he has to query his supply chain, but is not allowed to ask for more than the VS – so he queries exactly the VS. For the KMU it solves an efficiency problem: Instead of twenty different questionnaires, it answers the VS once and serves all. For Banks it creates a comparable database for credit lending and portfolio management.
If all three sides want the same format, a standard emerges – whether it's called „voluntary» or not. The realistic roadmap: a Adaptation phase from September to December 2026, in which the first major companies begin to request the VS from suppliers. From 2027 will the VS become the de facto standard across the entire EU in the „large corporation ↔ SME» relationship. Those who do not have a solid, source-based VS database by then will be negotiating from a defensive position in every tender.
Where caution is advised
„De facto mandatory» remains a forecast, not a legal fact. The delegated act is still undergoing the scrutiny phase by Parliament and Council (up to four months), and minor changes are possible. Market penetration will depend on how consistently large corporations actually anchor VS as a procurement standard. The direction is clear – the pace is not yet.
4. What that means for small and medium-sized enterprises
For an SME, the crucial question is not „Am I subject to reporting obligations?» but rather „Can I deliver what my largest customer and my bank will require as standard from 2027 onwards?». The ZEROvia approach is tailored precisely to this question. Instead of a cumbersome reporting tool, it offers a pragmatic three-step process that leads a company from scratch to a VS-compliant database – with every statement being source-bound, auditable, and reusable.
Capture. Detect. Improve.
The pragmatic path to the VS report – from a free start to a bank-ready data basis.
1. ESG Quick Check20 questions, immediate score and maturity level. Free, in minutes – the low-threshold entry point that shows where a company stands.
2. ESG AssessmentEvidence-based rating based on 48 questions. No score without documented proof of sources – a reliable assessment as the basis for the report.
3. VS-ReportFrom the validated data model, the VS-compliant report is generated, with which a company meets the standardized requirements of major clients and banks – auditable and reusable.
Ready for the VS standard?
‚Start with the free Quick Check.
The point isn't that ZEROvia is another reporting tool. The point is the data foundation behind it: a verified, source-linked data model, from which both the private VS report for banks and large customers, as well as a public, AI-readable ESG profile can be generated. If VS becomes the standard for data exchange, the winner will not be the one who reports the most, but the one who has cleanly captured their evidence once and can reuse it as often as desired.
For medium-sized businesses, the VS is therefore not a threat, but a self-announced simplification. Companies that organize their data now will not be frantically filling out questionnaires in 2027. They will deliver at the push of a button.
The VS (Voluntary Standard) is the binding version of the voluntary sustainability standard for companies outside the scope of the CSRD, adopted on July 3, 2026, as a delegated legal act (C(2026) 5011 final). In terms of content, it is based on the VSME, which EFRAG submitted in December 2024 and which the Commission adopted as a recommendation in July 2025. The central difference is its legal status: a non-binding recommendation becomes binding EU law, which simultaneously serves as a legal upper limit („Value Chain Cap») for data requests to SMEs.
No. The application remains voluntary for the SME itself. The standard is binding for the other party: large customers subject to CSRD may not request sustainability data from suppliers with fewer than 1,000 employees that goes beyond the VS. In practice, the VS therefore becomes the de facto requirement profile if an SME wants to serve large customers or banks.
The Value Chain Cap is a legal limit introduced with the Omnibus I package: Reporting companies may only request information from SME business partners (under 1,000 employees) to the extent of the VS standard. SMEs have a legal right to refuse requests beyond this.
The delegated act was adopted by the Commission on July 3, 2026, and is undergoing the scrutiny period by the European Parliament and Council (up to four months). Practical application is expected from the 2027 financial year, with voluntary early application possible from FY 2026. Market observers anticipate an adjustment period starting in autumn 2026 and widespread enforcement from 2027.
The standard has a two-tier structure: a basic module (B1–B11) with the most frequently requested key figures – including GHG emissions Scope 1 and 2, workforce, energy, and governance data – and a comprehensive module (C1–C9) with additional data frequently requested by banks and large customers. A double materiality assessment and an external audit are not mandatory.
Footnotes / Sources
- European Commission, Delegated Act C(2026) 5011 final, Brussels, 3.7.2026 (Primary document): ec.europa.eu/finance/docs/level-2-measures/csrd-delegated-act-2026-5011_en.pdf
- European Commission, „Commission seeks feedback on revised sustainability reporting standards» (May 6, 2026): finance.ec.europa.eu
- European Commission, „Q&A: Recommendation on a voluntary sustainability reporting standard for SMEs»: finance.ec.europa.eu
- European Commission, „Commission presents voluntary sustainability reporting standard to ease burden on SMEs»: finance.ec.europa.eu
- EFRAG, VSME Standard (December 2024): efrag.org – VSME Standard (PDF)
- EFRAG, „SMEs and Sustainability Reporting»: efrag.org
- Deloitte, „EU Sustainability Reporting — Omnibus Legislative Developments and Updates to ESRS» (January 14, 2026): dart.deloitte.com
- PwC, „’Omnibus‘ Directive Finalised» viewpoint.pwc.com
- Covington (Inside Energy & Environment), „European Commission Publishes ‚ESRS 2.0‘ for Public Consultation» (5/2026): insideenergyandenvironment.com
- Generation Impact Global, „VSME and the SME pathway: trickle-down cap explained»: generationimpact.global
This post is for informational purposes only and does not constitute legal or expert advice. The legal status and detailed content of the delegated act may still change during the examination phase by Parliament and Council; the final version published in the Official Journal will be decisive.