Since 18 March 2026, Omnibus I has removed thousands of companies from the scope of the CSRD. A company with 300 employees and €80 million in revenue no longer needs to prepare an ESRS sustainability report, conduct a double materiality assessment, or obtain assurance.
But that does not remove the need to provide sustainability data. On 3 July 2026, the European Commission adopted the new Voluntary Standard, or VS, built directly on EFRAG’s earlier VSME framework.
The VS remains voluntary for companies outside CSRD scope, but it defines the legal Value Chain Cap for CSRD-related data requests. Companies subject to CSRD reporting can still ask suppliers for sustainability information, but the information they require must remain within that framework. Being outside CSRD scope does not mean being outside sustainability risk.
Regulation left. Expectations did not.
Here is where many companies are making a critical reading error. They confuse “I am not legally required to report” with “I do not need to have my data in order.” Those are very different things.
Companies subject to CSRD reporting, the ones actually in CSRD scope, need information from their supply chain to complete their own report. You are part of that supply chain. The law may not require you to publish an ESRS report, but your customer may still need sustainability data from you. What has changed is how much information that customer can require for CSRD reporting purposes.
Banks and investors may request sustainability data for financing, risk-management or investment purposes. Those requests are generally outside the CSRD Value Chain Cap.
The Value Chain Cap applies specifically to requests made for CSRD reporting. It does not automatically limit information requested by banks for lending and risk-management purposes, or information requested under another legal or contractual obligation.
And then there are investment funds. ESG mandates remain active. Asset managers need comparable, reliable information to justify their investment decisions to their own regulators. That your company is not legally bound to report does not make it invisible to capital markets.
From VSME to VS: voluntary for suppliers, binding for requesters
In December 2024, EFRAG published the Voluntary Sustainability Reporting Standard for SMEs, better known as VSME. It was designed for companies outside CSRD scope that still needed a structured way to respond to sustainability data requests.
On 3 July 2026, the European Commission formally adopted a delegated regulation establishing the new Voluntary Standard, or VS. The VS is built directly on EFRAG’s VSME work, but it is now the designated reference framework for a broader group of companies outside mandatory CSRD reporting, including businesses with up to 1,000 employees.
The distinction between voluntary and binding is important. Applying the VSME remains voluntary for the smaller company. However, the standard establishes the Value Chain Cap that a CSRD-reporting company must respect when requesting information from suppliers and other value-chain companies whose average number of employees did not exceed 1,000 during the preceding financial year.
In practical terms, a company reporting under the CSRD cannot require a protected supplier to provide more information than the Value Chain Cap covers. If it asks for additional CSRD-related information, it must identify that information as exceeding the cap and inform the supplier of its statutory right to decline.
This turns the VS into more than another reporting framework. It gives smaller companies a common data model and legal protection against disproportionate CSRD questionnaires, conflicting definitions, and repeated requests for information beyond the statutory limit.
The Commission adopted the delegated regulation on 3 July 2026. It will become legally effective after the European Parliament and Council scrutiny period and publication in the Official Journal. For CSRD value-chain reporting, it will apply from financial year 2027.
What they will ask for and what you should have ready
You do not need to build a complete CSRD report. But you do need to have a minimum data package you can share when asked and that is credible.
The VS retains a modular structure consisting of a Basic Module and a Comprehensive Module. The Comprehensive Module builds on the Basic Module, allowing companies to develop their reporting progressively without creating a full ESRS reporting function.
This is what we see large companies most frequently asking from their suppliers:
Carbon footprint: Scope 1 and 2 at minimum, ideally with relevant Scope 3 information. You do not need a full audit, but you need a recognizable methodology such as the GHG Protocol and traceable data.
Reduction plan: Not a 50-page document. Some targets quantified over 3–5 years with the main actions you will take. RD 214/2025 does not automatically apply to every company outside the scope of the CSRD. However, it may impose separate carbon-footprint and emissions-reduction plan obligations on companies that meet the criteria established under Article 11 of RD 214/2025 and Law 11/2018.
Basic policies: Environment, labor rights, and governance. They do not need to be perfect. They need to exist and be coherent with what you do.
Supply chain data: If you are a supplier to a CSRD-scope company, that company may need your data for its own reporting, including its Scope 3 disclosures. The VS now provides the shared framework for these requests and sets the maximum information that the customer can require under the Value Chain Cap.
In practice, the most useful approach is to prepare a VS-aligned core dataset containing the information covered by the standard. Additional indicators may still be requested by banks, investors, or customers for purposes unrelated to CSRD reporting, but those requests should be clearly separated from the statutory Value Chain Cap.
The cost of doing nothing
There is a scenario we see repeat. The company falls out of CSRD scope, management interprets it as “we no longer have to report,” and the sustainability team, if it exists, loses budget and priority.
Six months later, a major customer sends an ESG questionnaire for its CSRD reporting. The company does not know which questions fall within the Value Chain Cap, which exceed it, or where the requested data is stored. At the same time, a bank asks for climate information to renew a credit line, and that request may fall outside the protection offered by the CSRD cap.
The cost is not a fine. The cost is losing a contract, paying more for financing, or being excluded from a procurement process. These are invisible costs until they hit you. And when they do, there is no quick way to recover lost time.
The VS protects smaller companies from excessive CSRD data demands. It does not eliminate the commercial need to maintain reliable sustainability information.
What you can do today
First, stop thinking of this as “complying with regulation” and start thinking of it as “having my data ready for when they ask.” The mindset shift matters because it changes the urgency.
Map who asks you for ESG data today: customers, banks, investors, and partners. Identify why each organization needs the information. A request made for CSRD reporting is governed by the Value Chain Cap, while a financing, procurement, or contractual request may follow different rules.
Map the data you already have against the Basic and Comprehensive Modules of the VS. Identify which disclosures you can answer, where the supporting evidence is stored, and which gaps could delay a future response.
Centralize the collection of emissions, energy, waste, and water data. Not in an Excel file that only one person understands, but somewhere any team member can access, update, and export.
If a CSRD-reporting customer requests information beyond the Value Chain Cap, ask it to identify which questions exceed the cap and confirm your right to decline the additional request.
And if you still do not have your carbon footprint calculated, start there. RD 214/2025 may already bind you, the VS includes greenhouse-gas information, and your customers will not wait for either.
Being outside CSRD scope is not being out of the game. The new VS gives you a common framework for preparing your information and a clearer legal boundary when large customers request it.