Delegated Regulation C(2026) 5011 under Directive 2013/34/EU (Art. 29ca); Value Chain Cap in Art. 19a(3) and Art. 29a(3) of Directive 2013/34/EU
VS instead of VSME: the voluntary standard and the Value Chain Cap
What large customers may still demand from you from now on — and what they may not. The new voluntary standard in plain language.
Status: adopted by the Commission on 3 Jul 2026 (Official Journal pending); includes the Value Chain Cap: a legal ceiling on what CSRD reporters may demand from suppliers with ≤ 1,000 employees from FY 2027
Relevant for: mid-sized suppliers in corporate supply chains — your answer standard and your legal limit
What is the VS?
The VS (Voluntary Standard for sustainability reporting by companies not subject to reporting obligations) is the EU reporting standard for companies outside the CSRD. The Commission adopted it on 3 July 2026 as a delegated regulation (C(2026) 5011); it replaces the previous VSME, which existed only as Recommendation (EU) 2025/1710. Publication in the Official Journal is still pending. The VS consists of a basic module (B1 to B11) and a comprehensive module (C1 to C9); a self-declaration is sufficient, no external assurance is required.
For the mid-market the VS matters for two reasons: it is the answer standard for responding to customer requests consistently. And it defines the Value Chain Cap, the legal ceiling on what CSRD-reporting customers may demand from you.
Who is affected?
- Companies with up to 1,000 employees in the value chain of CSRD-reporting customers: the Value Chain Cap applies to them. Customers may only request the data points marked as necessary in the VS for their CSRD reports.
- Companies with up to 10 employees: an even shorter list applies (Annex II of the delegated regulation).
- Companies that want to report voluntarily: banks, investors and customers increasingly ask for VS-compliant disclosures; the VS is the standard they expect.
Not affected: anyone with no business relationship to CSRD-reporting companies and no wish to report voluntarily. The VS is not a law with obligations, but a standard with protective effect.
The Value Chain Cap only works when customers request information for their CSRD reporting. What they need under other rules, such as emissions data for CBAM, geolocation data for the EUDR or proof of origin for the Forced Labour Regulation, they may continue to request.
What applies from when?
| Date | What applies |
|---|---|
| 30 Jul 2025 | Commission Recommendation (EU) 2025/1710 on the VSME |
| 18 Mar 2026 | Omnibus I Directive in force: Value Chain Cap anchored in Art. 19a(3) and Art. 29a(3) of the Accounting Directive |
| 3 Jul 2026 | Commission adopts the delegated regulation on the VS (C(2026) 5011); scrutiny period of Parliament and Council |
| pending | Publication in the Official Journal; entry into force on the third day after |
| 1 Jan 2027 | Value Chain Cap applies to financial years starting on or after this date |
Which concrete obligations arise?
For you as a supplier there are no obligations, but three options:
- Maintain the VS basic module: collect the data points B1 to B11 (including energy and emissions, water, waste, workforce, health and safety, code of conduct, incidents) once and update them annually. With that you answer most customer requests from one document.
- Comprehensive module where needed: C1 to C9 add strategy, human rights policy (C6) and confirmed incidents in your own workforce and value chain (C7). These are exactly the points corporations ask about as they prepare for the CSDDD.
- Check requests: if a CSRD-reporting customer asks for more than the necessary data points for its report, it must point out that the request is voluntary, and you may decline. This applies from financial year 2027.
For CSRD-reporting customers, the obligation arises to limit their supplier questionnaires to the cap or to mark excess questions as voluntary.
Common misconceptions
- Completing every corporate questionnaire in full. Many questionnaires date from before the Omnibus and contain data points the customer may no longer request. Delivering them anyway ties up capacity and sets precedents.
- Throwing away VSME reports. Anyone who has already reported under the VSME has essentially met the structure of the VS. The switch is manageable.
- Treating the cap as a free pass. The cap only limits CSRD requests. Product-related obligations (CBAM, EUDR, Battery Regulation, Forced Labour Regulation) run independently.
- Waiting for the Official Journal before collecting data. The data points are fixed. Collect in 2026 and you have the answers ready in 2027.
How SCRM Guard helps
On the platform, the disclosures of the VS basic module and the supply-chain-related points of the comprehensive module are held in a structured way: code of conduct, human rights policy, confirmed incidents in workforce and supply chain, supplier assessments. You answer customer questionnaires from the system, and the CSRD/CSDDD radar shows which questions fall under the Value Chain Cap.
In the full service we take over the data collection, the response to customer requests and the check whether a request is justified. We deliver both: the data and the knowledge of where the limit lies.
Frequently asked questions
What is the difference between VSME and VS?
What is the Value Chain Cap?
Can my customer still ask for more?
From when does the Value Chain Cap apply?
Sources
- European Commission: Delegated Regulation C(2026) 5011 (Voluntary Standard), full text (03 Jul 2026)
- European Commission: Value Chain Cap explained (06 May 2026)
- Commission Recommendation (EU) 2025/1710 on the VSME (predecessor) (30 Jul 2025)
This page is an editorial briefing for procurement and compliance teams in mid-sized companies, not legal advice. We check deadlines and thresholds against primary sources; the review date is shown at the top of the page.