Directive (EU) 2026/470 · in force 18 March 2026 · applies from FY2027
The EU value-chain cap
A CSRD-obligated company may not require more sustainability information, for its own CSRD reporting, from a supplier of up to 1,000 employees than the voluntary standard contains. For most mid-market suppliers this is the single most useful fact in the whole regime: the obligation now has a ceiling.
Last updated 2026-09-05
The dates, because they are widely misreported
- Directive (EU) 2026/470 was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026, the twentieth day after publication.
- Member States must transpose it into national law by 19 March 2027.
- The value-chain ceiling applies to reporting for financial years beginning on or after 1 January 2027, with early application permitted.
- On 3 July 2026 the Commission adopted delegated act C(2026) 5011, the voluntary reporting standard the ceiling points at. That date is the standard’s, not the directive’s, and the two are often reported as one.
What changed
The Omnibus package cut the population of companies inside the CSRD reporting mandate by roughly ninety per cent. Mandatory scope now turns on two thresholds together: more than 1,000 employees and more than €450m net turnover. Wave 2 moved to 2028, and listed small and medium companies were removed from scope entirely.
The part that matters to a supplier is separate from the reporting threshold. The directive also puts a ceiling on what an in-scope company may require down its value chain. If you employ no more than 1,000 people, a large customer cannot compel more than the voluntary standard contains, however large that customer is and however long their questionnaire runs.
One limit on the limit, and it matters in practice: the ceiling governs information requested for CSRD reporting purposes. It does not govern a commercial information exchange. A customer who asks for carbon data as a condition of a contract rather than for their own report is outside it, which is precisely why the requests do not stop.
What this does not mean
It does not mean the requests stop. Demand for carbon data moved from statutory to commercial: customer questionnaires, EcoVadis assessments, bank and lender ESG annexes, public and private tenders, CBAM and EUDR obligations further up the chain, and SBTi commitments. Those are contractual and competitive pressures, and the cap does not remove them.
What the cap changes is the shape of the work. Before it, a supplier faced an open-ended series of differently worded demands with no defensible stopping point. After it, there is a defined dataset that answers the statutory part, and everything beyond it is a commercial decision you make rather than an obligation you carry.
What you can be asked for
The basic module of the voluntary standard. In practice, for most suppliers, that is:
- Total Scope 1 emissions for the reporting period.
- Total Scope 2 emissions, location-based, for the same period.
- Energy consumption, broken down as the standard requires.
- The calculation method, including the standard applied and the GWP basis.
- The reporting period and the boundary the figures cover.
- Scope 3 only where you already report it. The ceiling does not oblige you to start.
How CoreCanopy answers it
The ledger produces the climate and energy figures the basic module asks for from records you already hold, and each figure carries the factor, dataset version, licence and audit entry that produced it. The same records answer the next request without a second data-collection exercise, which is the entire point of keeping a ledger rather than rebuilding a spreadsheet each year.
To be exact about what that is and is not: there is no one-click "voluntary standard report" in the product. There are the figures, their method, their period and their evidence, ready to be typed into whichever form the request arrives on. GRI 305, ESRS E1 and the UK Carbon Reduction Plan under PPN 006 are the three frameworks CoreCanopy files as documents.
This page describes our reading of the instrument, in plain language, for a non-lawyer. It is not legal advice, and where your own obligations are unclear you should take advice on them.