What does sustainability mean for a Swiss SME?
On 3 July 2026, the European Commission adopted the voluntary sustainability standard as a delegated act. It looks harmless: "voluntary". In fact, it decides which ESG data an SME in the supply chain still has to provide at all. Here is the context.
Anyone who has followed European ESG regulation since the first CSRD consultation has learned to distrust announcements and look at the mechanics. 3 July 2026 was one of those days when the mechanics mattered more than the headline. With delegated act C(2026) 5011 final the European Commission adopted the voluntary sustainability standard for companies outside the CSRD obligation: the binding version of what had until now been circulating on the market as the VSME recommendation. In expert circles the abbreviation "VS" (Voluntary Standard) has quickly caught on. The real news is not in the title: a "voluntary" standard becomes the binding ceiling for everything large buyers and banks may demand from smaller suppliers.
This sounds like a technical detail. It is the reason why the VS will matter more to the SME sector over the next 18 months than the CSRD itself.
1. Where the CSRD stops and how Omnibus changed it
The Corporate Sustainability Reporting Directive (CSRD) was, in its original version, designed for around 50,000 companies in the EU. It requires an audited sustainability report under the ESRS (European Sustainability Reporting Standards), including a double materiality assessment and external assurance. For a large, capital-market-facing company that is demanding but manageable. For the traditional SME sector it was too big from the start.
This is where the Omnibus I package came in. The Commission proposed it on 26 February 2025; the corresponding amending directive was finally adopted in early 2026 and entered into force in spring 2026. Three changes are decisive for the SME sector:
First, the scope. The CSRD obligation now only applies to companies with more than 1,000 employees and over EUR 450 million in turnover. This dramatically reduces the number of companies subject to reporting. Estimates point to a reduction of around 80%. Most of the SME sector is therefore formally out of the direct obligation.
Second, the streamlining of the ESRS. The revised standards reduce the number of data points from around 1,073 to about 320 (where material), a reduction of over 70%, and of more than 60% for the mandatory data points. However, double materiality, ESRS 1 and 2 as the mandatory framework and E1 (climate) as the data backbone remain. The CSRD is therefore simpler, but not fundamentally different.
Third, and this is the real lever, the "Value Chain Cap". A CSRD-obligated company may no longer demand sustainability information from business partners with fewer than 1,000 employees that goes beyond the voluntary standard. A recommendation thereby becomes a statutory cap. The VS is no longer just an offer to SMEs. It is the legal limit on what may be requested from them.
A critical view
The cap protects against mandatory data requests beyond the VS, but not against voluntary ones. Large buyers may still ask for more, and for commercial reasons many SMEs will deliver. Banks, too, sometimes operate outside the value chain logic through their own regulatory requirements. "All requirements met" is therefore more precise than "all standardised requirements met".
Where the CSRD obligation ends, the VS standard begins
MANDATORY
CSRD
≥ 1,000 employees AND
> EUR 450 million turnover
- Full ESRS (~320 data points, where material)
- Double materiality assessment
- External assurance requirement
VOLUNTARY · CAPPED
VS standard (based on VSME)
< 1,000 employees
outside the CSRD obligation
- Basic module B1–B11 (core KPIs)
- Comprehensive C1–C9 (on request)
- No mandatory materiality assessment, no audit requirement
VALUE CHAIN CAP (Omnibus I)
A CSRD-obligated company may not demand anything from SME suppliers that goes beyond the VS standard
Fig. 1: Boundary between CSRD and VS standard. The value chain cap makes the voluntary standard the binding ceiling for data requests along the supply chain.
2. From VSME to VS: how a "voluntary" standard gets teeth
The VS did not come out of nowhere. Its history explains why it carries such weight. In December 2024, EFRAG handed the VSME (the "Voluntary Sustainability Reporting Standard for non-listed SMEs") to the Commission. It was the pragmatic answer to a real problem: customers and banks were flooding SMEs with a jungle of individual ESG questionnaires. The VSME was meant to replace this jungle with one standardised disclosure.
In July 2025 the Commission adopted the VSME as a recommendation. Under EU law, a recommendation is "soft law": non-binding. Omnibus changed exactly that. The VSME went from friendly advice to the legally anchored reference point for the value chain cap. And with the delegated act of 3 July 2026, this version now gains binding legal force as a delegated regulation: no longer advice, but applicable law.
The content structure of the VSME largely remains intact: a basic module (B1–B11) with the core metrics that value chain partners request most often, including GHG emissions Scope 1 and 2, metrics on the company's own workforce, energy and anti-corruption. Building on this, a comprehensive module (C1–C9) covers the additional disclosures that banks, investors and large buyers typically request on top. The basic module is a prerequisite for the comprehensive module.
The VS is not a "new" standard, but the VSME with legal teeth. The disclosures barely change in substance; what changes is the legal status (recommendation → delegated regulation) and the function (template → statutory data limit). Anyone who understands this will position themselves correctly before the market does.
The key differences: VSME (2024/25) → VS (2026)
| Dimension | VSME (EFRAG recommendation) | VS standard (delegated act) |
|---|---|---|
| Legal status | Commission recommendation (soft law), 30 July 2025 | Delegated regulation: binding EU law, C(2026) 5011 final of 3.7.2026 |
| Bindingness | Non-binding, purely voluntary application | Voluntary for the SME, but binding as a ceiling for requesters |
| Role in the supply chain | Standardised response template against questionnaire sprawl | Statutory "value chain cap": defines the maximum permissible requests |
| Protection for SMEs | None: customers could demand as much more as they liked | Yes: statutory right to decline requests beyond the VS |
| Module structure | Basic B1–B11 + Comprehensive C1–C9 | Largely carried over (based on VSME in content) |
| Double materiality | Not mandatory | Not mandatory (deliberately low-threshold) |
| External assurance | No assurance requirement | No assurance requirement |
| Relationship to CSRD/ESRS | Deliberately "lighter" than ESRS | Reference point that ESRS reporters may not exceed when dealing with SMEs |
| Status & timeline | Handed over 12/2024, recommendation 07/2025 | Adopted 03.07.2026; review by Parliament and Council (up to 4 months); application from FY 2027, voluntary from FY 2026 |
The exact number of VS data points varies depending on how they are counted and on the final annex to the act; figures in circulation range from around 46 frequently requested basic data points to about 140 data points across both modules. The final version must be checked against the published annex.
3. Why the VS is becoming the de facto data exchange standard
Regulation rarely has its effect where it formally applies, but where market behaviour changes. The VS hits a nerve because it serves three interests at once. For the large corporation it solves a compliance problem: it must query its supply chain but may not demand more than the VS. So it asks for exactly the VS. For the SME it solves an efficiency problem: instead of answering twenty different questionnaires, it answers the VS once and serves everyone with it. For banks it creates a comparable data foundation for lending and portfolio management.
When all three sides want the same format, a standard emerges, whether or not it is called "voluntary". The realistic timetable: an adjustment phase from September to December 2026, in which the first large companies start requesting the VS from suppliers. From 2027 the VS will become the de facto standard across the EU in the relationship between "large company ↔ SME". Anyone who does not have a robust, source-backed VS data foundation by then will be negotiating from a defensive position in every tender.
Where caution is warranted
"De facto mandatory" remains a forecast, not a legal fact. The delegated act is still going through the review by Parliament and Council (up to four months), and detailed changes are possible. And market uptake depends on how consistently large companies actually anchor the VS as a procurement standard. The direction is clear. The pace is not yet.
4. What this means concretely for the SME sector
For an SME, the decisive question is not "Am I subject to reporting?" but "Can I deliver what my largest customer and my bank will request as standard from 2027?" The ZEROvia approach is built precisely for this question. Instead of a heavyweight reporting tool, a pragmatic three-step process takes a company from zero to a VS-ready data foundation. Every statement is source-backed, auditable and reusable.
Capture. Evidence. Improve.
The pragmatic route to the VS report: from the free starting point to a bank-ready data foundation.
1. Baseline assessmentFour free baseline assessments: ESG, procurement, PPWR readiness and DPP readiness. In minutes you see where your company stands.
2. ESG self-assessment49 questions, without a score. Every answer with a source or evidence: the robust data foundation for the report.
3. VS reportThe VS-compliant report is generated from the verified data model, allowing a company to meet the standardised requirements of large buyers and banks, audit-ready and reusable.
Ready for the VS standard?
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The point is not that ZEROvia is another reporting tool. The point is the data foundation behind it: a verified, source-backed data model, from which both the private VS report for banks and large buyers and a public, AI-readable ESG profile can be generated. When the VS becomes the data exchange standard, the winner is not whoever reports the most, but whoever captures their evidence cleanly once and can reuse it as often as needed.
For the SME sector, the VS is therefore not a threat but a simplification with a clear signal. Companies that get their data in order now will not be filling in questionnaires in a panic 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 CSRD obligation, adopted on 3 July 2026 as a delegated act (C(2026) 5011 final). In content, it is based on the VSME, which EFRAG presented in December 2024 and which the Commission adopted as a recommendation in July 2025. The key difference is legal status: a non-binding recommendation becomes binding EU law, which also serves as a statutory cap ("value chain cap") on data requests to SMEs.
No. For the SME itself, application remains voluntary. The standard is binding on the other side: CSRD-obligated large buyers 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 buyers or banks.
The value chain cap is a statutory ceiling introduced with the Omnibus I package: reporting companies may only request information from SME business partners (with fewer than 1,000 employees) to the extent of the VS standard. SMEs have a legal right to decline requests that go beyond it.
The delegated act was adopted by the Commission on 3 July 2026 and is going through review by the European Parliament and Council (up to four months). Practical application is expected from financial year 2027, with voluntary early application from FY 2026 possible. Market observers expect an adjustment phase from autumn 2026 and broad enforcement from 2027.
The standard has two levels: a basic module (B1–B11) with the most frequently requested metrics, including GHG emissions Scope 1 and 2, workforce, energy and governance disclosures, and a comprehensive module (C1–C9) with additional disclosures that banks and large buyers often require. A double materiality assessment and external assurance 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" (6.5.2026): 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" (14.1.2026): 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 article is for information only and does not replace legal or audit advice. The legal status and detailed content of the delegated act may still change during the review by Parliament and Council; the final version published in the Official Journal is decisive.