Your large customers can ask for ESG data — but not unlimited data.
Under the current EFRAG framework, CSRD-reporting buyers are expected to keep ESG data requests to SME suppliers within the voluntary VSME Essential scope. Here is what that looks like in practice, and what to say when a questionnaire goes further.
Based on the current EFRAG VSME standard (v1.3.0, June 2026) and the CSRD framework. This page is a summary for SMEs, not legal advice.
What this means for you
Large EU buyers (CSRD reporters) are expected to keep ESG requests to SME suppliers within a defined scope — the VSME Essential (Basic Module) disclosures.
The scope covers general company information, energy and emissions, workforce, and core governance — not full corporate-level ESG reporting.
If a request goes beyond that scope, you can offer the standard disclosures first and treat the additional items as a case-by-case discussion.
The framework does not compel a buyer to source from you — but it does tell them what is proportionate to ask.
EcoDiligence stays inside the Essential scope by default, so a Free-tier ESG Passport already answers what most buyers are entitled to request.
What the value-chain limit actually says
The Corporate Sustainability Reporting Directive (CSRD) requires large European companies to disclose sustainability information about their own operations and about their value chain. Naturally, they turn to their suppliers for the data.
To keep that request proportionate, EFRAG's implementation guidance and the European Sustainability Reporting Standards (ESRS) point to a specific limit: when a supplier is a non-listed small or medium enterprise, the CSRD reporter should not require disclosures beyond the Voluntary SME Standard (VSME) Essential (Basic) module. That is the “value-chain cap” SME advisors talk about.
The VSME standard itself was published by EFRAG in June 2026 as a voluntary framework — SMEs choose to adopt it, buyers choose to accept it. What makes the cap operative is the buyer's own CSRD reporting obligation on the demand side: they need proportionate data, not maximal data.
Some disclosures inside the VSME framework are optional even at the Essential level — for example, several disclosures do not apply to micro-entities (typically ten employees or fewer). The Comprehensive Module is entirely optional and sits above the cap; nobody can require it from you.
What's inside the scope, and what's outside
A simplified view of the areas the VSME Basic Module covers versus items that fall outside its scope and are therefore optional for an SME to provide.
Topic
Essential (Basic Module)
Outside VSME scope (optional to provide)
Company profile
Basic identifiers, sector, size, location
Full corporate structure, beneficial ownership, sensitive ownership disclosures
Energy & Scope 1/2 emissions
Total energy, renewable share, Scope 1 & 2 GHG emissions
Full Scope 3 inventory with granular category-by-category breakdown
Waste & pollution
Total waste generated, hazardous vs non-hazardous split
Individual salary bands, disciplinary records, personal identifiers
Governance & ethics
Presence of code of ethics, anti-corruption and anti-harassment policies
Full board minutes, internal audit reports, litigation registers
Value chain
Description of principal customers, suppliers, and business model
Full supplier list with commercial terms and contract copies
Targets & strategy
Voluntary — you may share reduction targets if you have set them
Full transition-plan narrative, scenario analysis, capex allocation (Comprehensive-only)
Simplified view for SME orientation. The authoritative wording lives in the EFRAG VSME standard (Basic and Comprehensive modules) and the European Sustainability Reporting Standards (ESRS). Framework text prevails wherever this summary is ambiguous.
What to say to a demanding customer
Three short replies you can adapt. The tone is deliberately calm and cooperative — the goal is to redirect the conversation to a standard-aligned Passport, not to escalate.
1. Share what's inside the VSME scope
Use when: Your buyer sent a long questionnaire. Start here — offer the standard-aligned data first, before discussing anything beyond it.
Hello,
Thank you for the ESG data request. We have prepared our disclosures using the EFRAG Voluntary SME Standard (VSME) — the standard EFRAG has developed for SME reporting to value-chain partners.
You can access our ESG Passport here:
[insert your EcoDiligence public profile link]
The Passport covers energy, Scope 1 and Scope 2 emissions, workforce data, and governance policies — the areas the VSME Basic Module addresses. If you need the data in a machine-readable format (Excel / XBRL), we can send that as well.
Please let us know if this covers what you need.
Best regards,
[Your name]
2. Politely decline items outside the standard scope
Use when: The buyer follows up asking for items that clearly fall outside the VSME Basic Module — full Scope 3, detailed pollutant registers, supplier lists, etc.
Hello,
Thank you for the follow-up. We have reviewed the additional items and a number of them fall outside the scope of the EFRAG VSME standard that structures our disclosures.
Under the current EFRAG framework, the VSME Essential (Basic Module) sets out what is expected of SME suppliers in the value chain of larger reporters. We would prefer to keep our disclosure within that scope so it stays comparable and audit-ready across all our customers.
If any of these items are essential for your reporting, we are happy to discuss them individually — please let us know which are must-haves for your compliance work, and we will see what we can prepare.
Best regards,
[Your name]
3. Ask the buyer to confirm the VSME scope
Use when: The questionnaire looks like a generic large-enterprise template. Redirect the conversation by asking the buyer to confirm the framework limit that applies to them.
Hello,
Before we work through the questionnaire, could you help us align on scope?
Our ESG disclosures follow the EFRAG Voluntary SME Standard (VSME), which is the framework designed for SME suppliers reporting into the value chain of larger CSRD reporters. Under the current EFRAG framework, requests to SME suppliers are expected to remain within the VSME Essential (Basic Module) scope.
Could you confirm that the questionnaire is aligned with this scope, or let us know which items are outside it and why they are needed? This will help us reply with the right level of detail without over- or under-reporting.
Best regards,
[Your name]
How EcoDiligence keeps you inside the scope
Essential-by-default
The standard wizard collects only VSME Basic Module data points. Anything deeper lives in a separate, opt-in Advanced Disclosures layer.
Shareable Passport + PDF
A permanent public URL and a branded PDF you can send to any buyer. Both carry the same standards-aligned data and self-report attestation.
Advanced disclosures on your terms
If you choose to share more, the Pro plan adds optional VSME Comprehensive and IFRS S2 transition topics — always your choice, never compelled.
Machine-readable exports
Buyers who need structure receive the VSME Digital Template (Excel) or an XBRL feed — from the same source of truth as your Passport.
Create your free Passport — most SMEs finish in under ten minutes and can share the link the same day.
Frequently asked questions
This page summarises the current EFRAG VSME framework and related CSRD guidance for orientation only. It is not legal advice and does not create any rights or obligations. Framework wording may change; always check the official texts at efrag.org and the European Commission's CSRD pages. EcoDiligence ESG Passports are self-reported summaries structured for ESG disclosure workflows. Content is not independently assured. Information aligned with EFRAG VSME and IFRS S2 (ISSB) frameworks does not constitute formal compliance or certification.
Ready to answer buyer requests the smart way?
Generate a shareable ESG Passport aligned with the VSME Essential scope — free, no consultant, ~10 minutes.