Does the value chain cap in the Corporate Sustainability Reporting Directive (CSRD) treat a 10-person supplier differently from a 500-person one?
Yes. The Commission's 6 May 2026 Q&A, written on the draft, says buyers can only require disclosures marked "necessary", and some of those are marked voluntary for companies with 10 employees or fewer. The cap covers less for the smallest suppliers. The act was adopted on 3 July 2026, so check its Annexes for the split.
How the standard is built, as the Q&A describes the draft
- Two modules: a basic module, designed for the smallest companies (micro-undertakings), and a comprehensive module that builds on it.
- The basic module is a pre-requisite for applying the comprehensive module.
- Each disclosure sits in one of four categories: "necessary", "necessary if applicable", "voluntary", and "consideration when reporting sector information".
What a buyer can require
The Q&A says the draft delegated act specifies that CSRD companies can only require value chain companies to provide the information for disclosures marked "necessary". They may not require the other three categories. The value chain cap therefore includes every disclosure marked "necessary" in both the basic and comprehensive modules.
The two headcount tiers
- For reasons of proportionality, some disclosures marked "necessary" for companies with 11 to 1000 employees are marked "voluntary" for companies with 10 employees or fewer.
- So the cap for 10 employees or fewer includes less information than the cap for 11 to 1000 employees. The Commission says the smallest companies are given extra protection from the trickle-down effect.
- The Q&A says Annex II of the voluntary standard delegated act, in its draft form, summarises which disclosures fall in the cap for each tier.
What to do
- Count your employees and note which tier you are in.
- Open the Annexes to the adopted delegated act and mark the disclosures that apply to your tier. Check that the Annex II split in the Q&A still matches the adopted text.
- Compare the buyer's questions with that list, and ask about any that fall outside it.
How this sits with the VSME pages
Other pages point to VSME, the Voluntary Sustainability Reporting Standard for non-listed small and medium-sized enterprises (VSME), from the European Financial Reporting Advisory Group (EFRAG), as a practical answer for small suppliers. The Commission's Q&A describes the cap through the Commission's own voluntary standard and does not name VSME, so do not assume the two disclosure lists are identical. Check the adopted Annexes. The Commission page on delegated acts under CSRD lists the act of 3 July 2026 as adopted and not in force until it is published in the Official Journal.
What Senseible does here
Senseible reads fuel invoices and electricity bills into monthly records, so the energy figures you choose to share come from your own bills. It does not decide what a buyer may ask or what a CSRD report must contain.
- Voluntary standard for small suppliers (VSME)
- Refusing a buyer request beyond VSME
- My buyer asks for my Scope 3
- Who is still in scope of CSRD
Sources: European Commission, Feedback on sustainability reporting standards: additional explanatory information regarding the value chain cap (6 May 2026), European Commission, Corporate Sustainability Reporting Directive: implementing and delegated acts (page last updated 3 July 2026)
Last reviewed 2026-11-05. From the Commission Q&A of 6 May 2026, written on the draft. The delegated act was adopted on 3 July 2026 and is not in force until it is published in the Official Journal, per the Commission page last updated 3 July 2026. We could not open the adopted Annexes, so check the tier split and the Annex II reference against them.