Buried inside this week's ESRS revision package is a measure that will change how large companies manage supplier sustainability data — and how much they can legitimately ask for. The European Commission has adopted a voluntary sustainability reporting standard for companies with up to 1,000 employees that fall outside the mandatory scope of the CSRD. From financial year 2027, that standard becomes the value-chain cap: the maximum amount of sustainability information that a larger, in-scope company may request from a smaller supplier.
The standard is structured around two modules. The Basic Module covers the essentials — greenhouse gas emissions, a limited set of environmental datapoints, workforce metrics, and anti-corruption disclosures. The Comprehensive Module adds further environmental and social information for companies that want or need to go further. The smallest companies, those with ten employees or fewer, can treat even some Basic Module disclosures as voluntary.
The practical implication for large companies is direct. From 2027, if you ask a supplier for more sustainability data than the voluntary standard covers, you are outside the value-chain cap and legally overreaching. Procurement teams and supply-chain sustainability functions need to map their current supplier data requests against the standard before that date, and redesign collection processes accordingly. Companies that have built their Scope 3 calculation methodology on detailed supplier-specific data will need to review what remains permissible — and what must be replaced with sector averages or estimates.
The voluntary standard is available now. The compliance deadline for aligning value-chain requests is financial year 2027.
Sources: EC Commission adopts revised sustainability reporting standards Detailed ESRS revision analysis