If I report under the voluntary standard the Commission adopted on 3 July 2026, will buyers that report under the Corporate Sustainability Reporting Directive (CSRD) stop sending me questionnaires?
No. The Commission's 6 May 2026 Q&A says that if you apply the voluntary standard you will have reported all that a CSRD company could require for its CSRD reporting, but it can still request more, including unrelated information. Using the standard is entirely voluntary, and buyers should request less if they do not need it all.
Is the standard compulsory?
No. The Commission says the voluntary standard is entirely voluntary, and the Omnibus I Directive states that the value chain cap does not impose or imply any obligation on any companies in the value chain to provide sustainability information. Companies not subject to CSRD do not have to report using it.
What reporting on it does
If a company applies the voluntary standard, it will have reported all information that a CSRD company could require it to provide for CSRD reporting purposes.
A reporting buyer could still ask for more: information unrelated to CSRD reporting, and CSRD-related information beyond the cap. For the second kind, the buyer must indicate what exceeds the cap and tell you that you have a statutory right to decline.
What buyers are expected to ask
The Commission says CSRD companies are not expected to ask every supplier for everything under the cap. It quotes recital 12 of the Omnibus I Directive: reporting undertakings should "only request information from undertakings in their value chain insofar as necessary", and "request less information than that specified in the standards for voluntary use if they do not need all the information in those standards".
Where the standard stands now
The 6 May 2026 Q&A described the draft that was out for public feedback. The Commission's page on delegated acts under CSRD, last updated 3 July 2026, lists the Commission Delegated Regulation of 3 July 2026 setting the standards for voluntary use by undertakings protected by the value chain cap, with its Annexes, as adopted and "not in force until it is published in the Official Journal".
Our reading: what to do with that
- A report on the standard covers the most a CSRD buyer can require of you for its CSRD reporting. It does not stop requests for other purposes, such as a buyer's own portal or a footprint request.
- Check the final Annexes, and whether the act has been published in the Official Journal, before you build a report to match it.
- The Q&A does not say the Commission's standard and the Voluntary Sustainability Reporting Standard for non-listed small and medium-sized enterprises (VSME), from the European Financial Reporting Advisory Group (EFRAG), list the same disclosures. Our page on the small supplier standard covers it.
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
- Who is still in scope of CSRD
- Does CSRD apply to an Indian company?
- Buyer carbon questionnaires: what your bills answer
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, which described the draft. The Commission's page on delegated acts under CSRD (last updated 3 July 2026) lists the standard as adopted but not in force until it is published in the Official Journal. Check the final Annexes before preparing a report to match it.