The EU has put the value chain cap into law. For CSRD reporting teams, the next job is to review supplier questionnaires before the cap applies in 2027.
Commission Delegated Regulation (EU) 2026/1560 was published in the Official Journal on September 21, 2026. It entered into force on September 24. Article 3, which sets the cap, applies to financial years beginning on or after January 1, 2027.
Under the revised CSRD framework, mandatory sustainability reporting applies to companies within the revised scope, while the new value-chain cap limits the sustainability information that these reporting companies can request from value-chain undertakings with an average of no more than 1,000 employees. The revised ESRS and value-chain cap establish the requirements that reporting teams need to consider when preparing for reporting periods beginning in 2027.
Key Highlights
- Regulation (EU) 2026/1560 has been in force since September 24, 2026.
- The cap applies from financial years beginning on or after January 1, 2027.
- It protects value-chain undertakings that averaged no more than 1,000 employees in the preceding financial year.
- Annex II sets two datapoint lists: one for undertakings with 10 employees or fewer, and one for those with more than 10.
- The cap covers only information gathered for CSRD reporting. It does not override other EU or national law.
- The Voluntary Standard is voluntary. It is not a new supplier reporting mandate.
What the cap covers
The cap is the upper limit of sustainability information that reporting companies may require from smaller value-chain undertakings. Article 1 measures size by the average number of employees during the preceding financial year, on the balance sheet date. Article 3 says the cap comprises only the datapoints in Annex II. Only essential datapoints fall under it.
Annex II has two lists. The list for undertakings with more than 10 employees is longer. It includes energy, greenhouse gas, water and waste datapoints. The list for undertakings with 10 employees or fewer has no environmental datapoints. It focuses on general company information and workforce metrics.
The regulation also states the intent behind the cap. Reporting companies should request information only as far as they need it. They should ask for less than the standard specifies when they do not need all of it.
The scope is narrow. The cap applies only to information gathering for sustainability reporting under national laws that implement the Accounting Directive. It does not affect requests needed under other EU or national law.
A voluntary standard, not a new supplier reporting mandate
The Voluntary Standard builds on EFRAG’s VSME framework. It gives smaller companies a proportionate way to share sustainability information with larger companies, banks and investors. Annex I states that the standard does not impose legal reporting obligations. Companies that apply it do not have to seek assurance.
The standard and the cap serve different purposes. The standard offers a reporting framework. The cap limits what covered requests can include. The regulation builds the cap into the standard, but that does not mean every supplier must prepare a sustainability report.
Banks and investors sit in a different position. The regulation only encourages financial institutions to keep requests made outside sustainability reporting to the information in Annex I.
Suppliers that choose to report can also use EFRAG’s practical guidance. EFRAG has published the updated guidance in English on its Knowledge Hub, with translations expected from November. XBRL International reports that EFRAG also plans to release an updated Digital Template in November.
How reporting teams can prepare their questionnaires
The following steps are practical preparation measures. The regulation does not require them.
1. Inventory the questions already being sent
Bring together the questionnaires used by sustainability, procurement, finance and external service providers. Include onboarding forms and recurring supplier assessments.
For each field, record its purpose, the requesting team and the disclosure or decision it supports. This makes duplicate questions easier to spot. It also surfaces fields kept from earlier reporting cycles with no clear current use.
2. Map individual fields to Annex II
Compare each question with the relevant Annex II datapoint and the supplier’s employee-size category. Use the exact datapoint reference, such as B3 for energy and greenhouse gas emissions. Avoid broad labels like “environmental information.”
A useful review register has five columns: questionnaire field, supplier category, reporting purpose, Annex II reference and proposed action. A field with no Annex II match needs a closer look. If it supports CSRD reporting, it may go beyond the cap for the suppliers the cap protects. Send uncertain mappings for legal or reporting review before you approve the revised questionnaire.
3. Review mixed-purpose questionnaires
A single form may combine sustainability-reporting questions with questions for procurement decisions or separate legal obligations. Identify each purpose clearly. Do not assume every question in an ESG questionnaire has the same legal basis. Where another obligation applies, record that basis and review the request against its own conditions.
4. Design a process for missing information
Before collection begins, decide how teams will record incomplete responses, assess their effect on disclosures and escalate unresolved issues.
Keep unavailable information distinct from a zero value or a confirmed “not applicable” response. Where the applicable reporting requirements permit estimation, record the method, the assumptions and the review. An unanswered questionnaire field should never silently become a reported fact.
5. Keep questionnaire changes traceable
Maintain the version sent to each supplier, the response received and any later corrections. Link the information used in reporting to its source and reviewer.
This gives you a practical way to explain why a question was asked, which response supported a disclosure, and what changed between collection and approval.
Managing value-chain information with EcoActive
EcoActive’s Value Chain Management capabilities connect upstream and downstream activities with sustainability data, material impacts, risks and opportunities, evidence and disclosures. EcoActive CSRD Reporting Software supports the reporting lifecycle, including data collection, disclosure preparation, review and assurance readiness.
Supplier engagement built in
Send editable, ready-made questionnaires built for ESRS and Scope 3. Suppliers respond free, with no licence, and can answer in their own language. Teams can adjust fields after their Annex II review.
Reminders, review and scoring
Send reminders and review requests from the platform. Each supplier receives a weighted ESG score with suggested engagement actions.
Traceability from source to disclosure
Every value chain figure stays linked to its source, methodology, assumptions, evidence and approvals. A dedicated audit view lets auditors review supplier data and evidence in the platform, supported by EcoActive’s Audit and Review capabilities.
Scope 3 connectivity
Connect relevant value chain data with the GHG Calculator for Scope 3 reporting, with each category tagged by method so every figure stays transparent.
For teams revising supplier questionnaires, the practical objective is a clear link between the information requested, its reporting purpose, the response received and the disclosure it supports. Approve each questionnaire only after you review the applicable legal limits as well as your reporting needs.
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