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Regulation · 25 October 2026

Value-Chain Cap: what your buyer may still ask from 2027

From financial year 2027, companies under the CSRD may only request the information of the voluntary standard from suppliers with up to 1,000 employees for their report. What this means for SMEs, and what the cap does not regulate.

For years the rule was: if you supply a large customer, you inherit its reporting obligations. The EU is now limiting this trickle-down effect. The rule is called the Value-Chain Cap, and it applies from the 2027 financial year.

What has been decided

  • Omnibus I Directive (EU) 2026/470, published in the Official Journal on 26.02.2026: in future the CSRD only applies to companies with more than 1,000 employees and more than EUR 450 million net turnover. Member states transpose the changes by 19.03.2027.
  • Delegated Regulation (EU) 2026/1560: the voluntary standard, developed from the VSME. The Commission adopted it on 03.07.2026; it has been in force since 24.09.2026.
  • Value-Chain Cap (Article 3): applies to financial years from 01.01.2027.

Who is protected

Companies in the value chain with an average of at most 1,000 employees that are not themselves subject to reporting. Micro-undertakings with up to 10 employees are additionally relieved: for them, further disclosures are voluntary, including energy and emissions (B3).

The cap binds the reporting customer. It limits what that customer may demand from its suppliers for its CSRD report. The directive does not restrict the protection to suppliers in the EU; however, it also contains no explicit rule for suppliers in third countries such as Switzerland.

What your customer may request

  • The disclosures marked as "necessary" in the voluntary standard (Annex II). Only these fall under the cap.
  • It may ask for more, but may not require it. It must mark which disclosures go beyond the cap, and point out your right to decline them.
  • Less is welcome. The Commission expects companies to ask for less when they need less.

What the cap does not regulate

  • Requests under other EU or national law, for example for the carbon border adjustment mechanism (CBAM) or the Packaging Regulation (PPWR). Product data remains in demand.
  • Due diligence obligations under the CSDDD. A separate limit applies there: information from business partners with fewer than 5,000 employees may only be requested if it cannot be obtained otherwise. The transposition deadline runs until 26.07.2028.
  • Requests for purposes other than the CSRD report, for example for supplier selection, and customers that are not subject to the CSRD.

What this means for you

  1. Record your data according to the voluntary standard. Then the answer to most reporting requests is ready, the same for all customers.
  2. Ask about the purpose of each request: CSRD report, due diligence, product regulation or supplier selection? This determines what you have to deliver.
  3. Beyond the cap you may decline, but you don't have to. Those who provide more, such as a carbon footprint or a PCF per item, can stand out in supplier selection.
  4. Decide for each customer what they see. The cap does not make your sharing superfluous; it makes it simpler.

How ZEROvia helps

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