Temps de lecture : x minutes
Ecrit par Matthieu Bruneau De La Salle
Value Chain Cap (CSRD): what you can (really) ask for
As part of theCSRD, the European Union introduces theValue Chain Capto limit what a company can ask of its suppliers. If this cap applies to theCSRD reporting, it will also become more widely imposed in client-supplier relationships.
Key takeaways from the article
- The Value Chain Cap limits the information that a company subject to the CSRD can require from its suppliers with fewer than 1,000 employees.
- The VSME becomes the reference standard for framing these ESG requests.
- Unlimited CSR questionnaires will no longer be compatible with CSRD reporting.
- Capping requests will gradually become a new norm in client-supplier relationships.
- Assessment tools will need to reconcile regulatory standardization and specific sectoral needs.
The Value Chain Cap: what exactly are we talking about?
TheValue Chain Capis a new rule established by the European Union, aimed at capping the information that a company subject to theCSRD(Corporate Sustainability Reporting Directive) can require from smaller companies (often SMEs/ETIs) in its value chain. The goal is to limit administrative burden and ensure greater consistencyin ESG information requests (Environment, Social, Governance). dans les demandes d’informations ESG (Environnement, Social, Gouvernance).
What is the Value Chain Cap?
The Value Chain Cap limits to voluntary reference standards, the VSME, what a company subject to the CSRD can require from companies with fewer than 1,000 employees in its value chain. These companies can refuse to respond to information requests beyond the standard.
The legislative framework: dates, objectives, and scope
The major legislative steps
TheValue Chain Capis part of theOmnibus Package, a series of legislative measures aimed at simplifying business regulation and their ESG reporting.
- 26 février 2025 : Publication du paquet Omnibus par la Commission Européenne, incluant des règles sur la CSRD et le Value Chain Cap (ec.europa.eu).
- 30 juillet 2025 : La Recommandation 2025/1710 sur la VSME est adoptée, proposant un standard volontaire pour les PME non cotées afin de simplifier leur reporting ESG (eur-lex.europa.eu).
- 9 décembre 2025 : Accord politique sur le Content Directive, qui définit le périmètre d’application des règles du Value Chain Cap (consilium.europa.eu) -(sustainablefutures.linklaters.com).
The official entry into force will occur 20 days after publication in the EU Official Journal, expected in early 2026.
What changes with the Value Chain Cap?
The Value Chain Cap limits the information requested from suppliers with fewer than 1,000 employees for CSRD reporting purposes. This helps reduce the administrative burden and standardize requests by using a voluntary framework: the VSME.
Who is affected by the Value Chain Cap?
Companies subject to the CSRD must ensure that the information required from their suppliers complies with the Value Chain Cap. This applies to companies with fewer than 1,000 employees (referred to as “protected undertakings”), which can refuse information requests exceeding what is provided in the VSME standard.
Découvrir la solution Scoring by Positive® ? En savoir moreThe VSME standard: what does it change?
The voluntary VSME standard
The VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs) is a framework proposed by EFRAG (European Financial Reporting Advisory Group), intended for non-listed SMEs/ETIs. It is based on proportionate ESG requirements designed to be tailored to the size of companies and their limited risk, while ensuring data comparability.
Why is the VSME becoming essential?
The VSME has become the reference for information requests to non-listed SMEs. The European Union encourages companies subject to the CSRD to base their requests on this standard to simplify the process and reduce the burden on small businesses.
Why will this standard prevail beyond the CSRD?
TheRecommendation 2025/1710encourages large companies to base their requests on the VSME standard, whether they collect it for CSRD reporting or not. This creates a de facto standard for all companies working with smaller suppliers. The Value Chain Cap will therefore become increasingly present in the client-supplier relationship, even if the request does not directly concern CSRD reporting.
Impact on CSR questionnaires: before and after the Value Chain Cap
Before: an “unlimited” request
Before the introduction of the Value Chain Cap, many companies imposed very detailed CSR questionnaires on their suppliers, without any real structure or limitation. The requests were sometimes extremely specific, leading to incomplete responses, refusals, or delays.
After: a capped CSR questionnaire
With the introduction of the Value Chain Cap, information requests for CSRD reporting will now need to be limited to a core of validated data, in order to avoid placing too much demand on suppliers with fewer than 1,000 employees. This will simplify questionnaires, improve the quality of responses, and promote better comparability of data.
Direct impact on questionnaires
Companies will need to simplify their CSR questionnaires by limiting requests to essential elements aligned with the VSME standard. This will improve the quality and comparability of responses and reduce friction with suppliers.
The impact on Scoring by Positive Company: standard vs customization
The standard block of Positive Company is 100% compatible with the Value Chain Cap
The standard block of Scoring by Positive Company is already aligned with the VSME. It is based on key, proportionate, and comparable ESG indicators, in line with the Value Chain Cap. This block allows companies to collect structured data that is both efficient and accessible for all sizes of suppliers, while complying with upcoming legislation. It can therefore be used for CSR maturity assessment as well as for CSRD reporting.
And the customized block?
The custom block from Scoring by Positive Company can go beyond the scope of the Value Chain Cap if it adds requests, detailed evidence, or granular data not covered by the VSME. This type of request may not be compatible with protected suppliers (≤ 1,000 employees) under the CSRD reporting, as they would be considered excessive according to the Value Chain Cap, but it would still be possible outside of it.
Specific requests outside of CSRD reporting
Specific requests such as sectoral or strategic questions are perfectly allowed when transmitted outside the framework of CSRD reporting. They are part of a classic client-supplier relationship and are not subject to the limitations imposed by the Value Chain Cap.
The Value Chain Cap: towards a new standard in the client-supplier relationship
Towards more consistent and simplified management of client-supplier relationships
While the Value Chain Cap primarily applies within the framework of the CSRD, it also becomes a good practice for companies looking to simplify and standardize their CSR requests to their suppliers. The VSME serves as an essential reference in client-supplier relationships, even if some more specific requests (sectoral or strategic) may justify the use of the custom block.
What this changes for Positive Company
Positive Company has adapted its scoring tool to offer a standard brick that is 100% compatible with the Value Chain Cap and the VSME. This allows companies to reduce administrative burdens while ensuring rigorous tracking of their suppliers' ESG commitments. For specific sectoral or strategic needs, the customized brick offers the possibility to go beyond the VSME, while remaining transparent and justified.
Discover the Scoring by Positive® solution? Learn moreConclusion
The Value Chain Cap will redefine how companies interact with their suppliers regarding ESG reporting, simplifying and structuring requests. Thanks to Positive Company, scoring becomes more standardized while remaining flexible to adapt to specific sectoral or strategic needs, and compatible with CSRD reporting. The transition to simplified reporting starts today: don't miss it.
No. The Value Chain Cap applies to companies subject to the CSRD when they request ESG information from suppliers with fewer than 1,000 employees. These suppliers can refuse to provide data beyond the VSME standard.
Outside of regulatory reporting (for example, for specific sectoral or strategic needs), additional requests remain possible within a traditional contractual framework.
However, with the Value Chain Cap, it becomes the de facto reference for framing ESG information requests addressed to unlisted SMEs and mid-sized companies.
Large companies will need to limit their requests to essential data, aligned with the VSME, in order to reduce administrative burden and improve the comparability of responses.