One-Page Summary

SME Rights under the VSME Value-Chain Cap

A quick reference for SME suppliers replying to ESG data requests from large European customers.

What the rule says

For a supplier of 1,000 employees or fewer, EU law bars a CSRD-reporting buyer from requiring more than a defined list — for that buyer's own CSRD reporting only, financial years from 1 January 2027, and once the buyer's own EU Member State has transposed Directive (EU) 2026/470 (due by ~26 Feb 2027). Commission Delegated Regulation (EU) 2026/1560's Annex II defines the exact list. Not for commercial or contractual requests; close to but not identical to the VSME Basic Module — see the size split below.

Inside vs outside the cap

The cap is narrower for smaller suppliers: several environmental items below are voluntary (outside the cap) for a supplier of 10 employees or fewer.

Inside the cap

General undertaking information and site geolocation — both tiers
Total energy, Scope 1 and location-based Scope 2 — 11–1,000 employees only
Total waste, circularity and recycling share; total water withdrawal — 11–1,000 employees only
Workforce by contract type and gender, accidents, minimum wage, collective bargaining, training hours — both tiers
Yes/No on a code of conduct/human-rights policy and a grievance mechanism; products, markets and main business relationships; employee turnover; confirmed human-rights incidents — 11–1,000 employees only

Simplified; see the full guide for the table. Policies on ethics, anti-corruption and anti-harassment are not in the cap at either tier.

Outside the cap (optional)

Full Scope 3 category breakdowns
Site-level pollutant registers
Salary data, disciplinary records
Full supplier list & contracts
Transition plan, scenario analysis

Ready-to-copy reply

Thank you for the ESG data request. We have prepared our disclosures using the EU Voluntary Standard (Annex I to Commission Delegated Regulation (EU) 2026/1560), which is based on EFRAG's VSME.

You can access our ESG Passport at [your public profile link]. It covers energy, Scope 1 & 2 emissions, workforce data, and governance — the areas the VSME Basic Module addresses.

If this request is for your own CSRD reporting, for a financial year beginning on or after 1 January 2027, and your Member State has transposed Directive (EU) 2026/470 into national law, EU law (that directive plus Regulation (EU) 2026/1560) limits what you may require from a supplier our size to a defined list. Items beyond that list are optional for us to provide — if any is essential for your reporting, please let us know and we will discuss it case-by-case.

How EcoDiligence helps

Standard wizard collects VSME Basic Module data by default — the baseline most first buyer requests need.
Shareable public Passport + PDF + the VSME Digital Template in Excel (EFRAG's converter turns it into XBRL).
Pro's Comprehensive layer reaches two cap items above the Free baseline — a clean Yes/No on the grievance mechanism, and what a code of conduct covers if you have one — plus anything further you choose to share, never compelled. Other Annex II items, such as employee turnover, are not collected in the VSME flow.
Free covers one Passport; editing it in place is free for as long as the account exists.