Directive (EU) 2026/470 · in force 3 July 2026
The EU value-chain cap
Since 3 July 2026, a CSRD-obligated company may not require more sustainability information from a supplier under 1,000 employees than the VSME 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 2026-09-04
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 caps what an in-scope company may demand down its value chain. If you employ fewer than 1,000 people, a large customer cannot compel more than the VSME standard requires, however large that customer is and however long their questionnaire runs.
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 VSME basic module. 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 cap does not oblige you to start.
How CoreCanopy answers it
The ledger produces every field of the basic module 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.
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.