For suppliers and SMEs

A customer is asking you for sustainability data. Now what?

A big customer has sent you a CSRD or ESG questionnaire and you have no sustainability team, no budget for software, and no idea whether you even have to fill it in. The good news: if your company has fewer than 1,000 employees, the rules are firmly on your side. This page explains whether you have to respond, what you can decline, and gives you three ready-to-send replies.

TL;DR

If your company has fewer than 1,000 employees, an in-scope customer cannot require you to provide more than the voluntary VSME standard (the value-chain cap). You are not obliged to complete a full-ESRS questionnaire. In practice it is usually smart to share VSME-level data to keep the relationship healthy, but anything beyond that is optional, and you can say no.

Do you even have to respond?

Whether you have to respond, and how much, depends almost entirely on your size. The CSRD was deliberately narrowed by the Omnibus directive so that the reporting burden falls on large companies, not their smaller partners.

  • Fewer than 1,000 employees

    The value-chain cap protects you. An in-scope customer may not require more than the VSME standard from you. You can share VSME-level data and decline the rest. A full-ESRS questionnaire is not something you are obliged to complete. Council, Omnibus sign-off (Feb 2026).

  • Over 1,000 employees but under EUR 450m turnover

    You are not a mandatory CSRD reporter (you need both thresholds), but the value-chain cap is written around the 1,000-employee line, so check carefully and negotiate. You may still choose to report voluntarily.

  • Over 1,000 employees AND over EUR 450m turnover

    You are likely an in-scope reporter yourself, not just a requestee. Use the scope checker to confirm, then head to the ESRS and double materiality pages.

The value-chain cap, plainly

The value-chain cap is the single most useful fact for a smaller supplier. It says: companies that are in CSRD scope may not demand sustainability data beyond the VSME standard from value-chain partners with fewer than 1,000 employees. It was added precisely to stop large reporters pushing their full reporting burden down onto small firms.

In practice that means you can read any monster questionnaire through one filter: is this within VSME? If yes, it is reasonable to answer. If no, you can point to the cap and decline, politely, using the templates below.

The detail is still being finalised

The VSME standard and parts of the Omnibus implementation are still being formalised through 2026 (the VSME delegated act is expected around mid-2026, and Member States must transpose the new rules by 19 March 2027). The core principle, the cap at 1,000 employees, is confirmed in the directive, but the exact VSME data points may shift a little. We track this in The CSRD Brief. EFRAG, VSME standard.

Copy-paste, free

Three replies you can send today

Plain-English and ready to send. Copy the text, swap in your details, hit send. No email or signup needed to use these.

Template 1: You are a small supplier (under 1,000 employees)

Use this when a customer sends a long sustainability questionnaire and your company has fewer than 1,000 employees.

Subject

Our response to your CSRD / sustainability data request

Body

Hi [Contact name],

Thanks for your sustainability data request. We want to help you meet your reporting obligations, so here is where we stand.

Our company has fewer than 1,000 employees. Under the CSRD as amended by the Omnibus directive, companies in your reporting scope may not require value-chain partners below 1,000 employees to provide more sustainability information than the voluntary VSME standard sets out. This is often called the "value-chain cap."

On that basis:
- We are happy to share the data points covered by the VSME standard (the basic module).
- For anything beyond VSME, we may not be able to provide it, and we are not required to.

If you can point us to which of your questions map to VSME, we will fill those in promptly. If it would help, we are also glad to send what we already track on energy, emissions and headcount.

Happy to talk it through.

[Your name]
[Your company]

Select the text above to copy it, then swap in the [bracketed] details for your situation.

Template 2: You will share VSME-level data

Use this to offer the data you can reasonably provide, on your terms, in a structured way.

Subject

Sustainability data we can provide (VSME basis)

Body

Hi [Contact name],

Following up on your request. Here is what we can share, set out against the voluntary VSME standard so it slots into your reporting:

- General information: business model, headcount, locations.
- Environment: energy consumption, Scope 1 and Scope 2 greenhouse-gas emissions where we have them, water and waste basics.
- Social: number of employees, health-and-safety incidents, basic workforce figures.
- Governance: any convictions or fines for corruption or bribery (none, in our case, unless stated otherwise).

We have used our best available figures and flagged any estimates. If you need a specific format (a spreadsheet template, a particular reporting period), send it over and we will fill it in.

For data points outside the VSME standard, please note the value-chain cap applies to us as a company with fewer than 1,000 employees, so we may not be able to provide those.

Best regards,
[Your name]
[Your company]

Select the text above to copy it, then swap in the [bracketed] details for your situation.

Template 3: Ask the customer to narrow the request

Use this when the questionnaire is huge, generic, or clearly built for a large reporter rather than a small supplier.

Subject

Quick question on your sustainability data request

Body

Hi [Contact name],

Thanks for sending the sustainability questionnaire. Before we invest time in it, could you help us scope it correctly?

We are a smaller company (fewer than 1,000 employees). Under the CSRD value-chain cap, companies in reporting scope can ask value-chain partners our size only for data within the voluntary VSME standard, not the full ESRS data set. A lot of the questions in your form look like full-ESRS items.

Could you let us know:
1. Which questions you actually need from a supplier of our size?
2. Whether the VSME basic module would meet your needs?
3. The reporting period and format you need?

Once we know that, we will turn the relevant answers around quickly. We would rather give you accurate VSME-level data than guess at items that do not apply to us.

Thanks,
[Your name]
[Your company]

Select the text above to copy it, then swap in the [bracketed] details for your situation.

How to handle the request well

Confirm your size first. The whole answer turns on whether you are under 1,000 employees. Get that straight before you respond, because it decides whether the value-chain cap applies to you.

Offer something, don't just refuse. Even when you can decline the full questionnaire, sharing VSME-level data, headcount, energy use, Scope 1 and Scope 2 emissions, keeps the relationship warm and is usually quick. A helpful partial answer beats a flat no.

Ask the customer to narrow the ask. Many large companies send the same generic full-ESRS form to every supplier. It is fair to ask which questions actually apply to a supplier of your size. Template 3 does this.

Keep a copy of what you sent. Save your response and the data behind it. If the same customer (or another) asks again next year, you can reuse it, and you have a record of what you provided and on what basis.

Optional

Want the printable kit?

The templates above stay free to copy. If you'd like a print-ready PDF kit, and a heads-up when the VSME standard and the rules change, leave your email.

Want the printable response kit (PDF) to keep? Enter your email and download it instantly.

The templates above are free to copy right now, no email needed. This gives you the print-ready PDF kit to keep and joins you to The CSRD Brief, our free plain-English newsletter, so you hear when the rules change. Unsubscribe any time, in one click.

Questions suppliers ask

Do I even have to respond to a CSRD data request?

Not necessarily. If your company has fewer than 1,000 employees, the CSRD value-chain cap means an in-scope customer cannot require you to provide more than the voluntary VSME standard contains. You are not legally obliged to complete a full-ESRS questionnaire. In practice you will often still want to share VSME-level data to keep the commercial relationship healthy, but you can decline anything beyond it.

What is VSME?

VSME is the Voluntary Sustainability Reporting Standard for SMEs, developed by EFRAG. It is a much shorter, simpler standard than the full ESRS, built for smaller companies that are not in mandatory CSRD scope. It also acts as the ceiling for what in-scope companies can demand from value-chain partners with fewer than 1,000 employees.

What is the value-chain cap?

The value-chain cap is a protection in the Omnibus directive. Companies that are in CSRD scope may not require sustainability information beyond the VSME standard from value-chain partners (suppliers, customers) that have fewer than 1,000 employees. It exists to stop the reporting burden trickling down onto smaller firms that the CSRD deliberately took out of scope.

My company is large. Am I in scope myself?

You are in mandatory CSRD scope only if you exceed both thresholds: more than 1,000 employees AND more than EUR 450 million net turnover. If you meet both, you are a reporter, not just a requestee, and you should use the scope checker and the ESRS pages. If you do not, the value-chain cap protects you when others ask for data.

Keep going

Am I in scope?

Check whether the CSRD applies to you, and which first-report year is yours.

What is the CSRD?

The plain-English explainer, post-Omnibus: who it covers and what it requires.

Emissions calculator

Work out the Scope 1 and 2 figures a customer may reasonably ask for.

Glossary

VSME, ESRS, double materiality and the rest of the acronyms, in plain English.

Check if you are in scope

Sources

  1. [1]Directive (EU) 2022/2464 (CSRD), on EUR-Lexretrieved 8 Jun 2026
  2. [2]Directive (EU) 2026/470 (Omnibus I), on EUR-Lexretrieved 8 Jun 2026
  3. [3]Council of the EU, Omnibus simplification sign-off, Feb 2026retrieved 8 Jun 2026
  4. [4]EFRAG, Voluntary Sustainability Reporting Standard for SMEs (VSME)retrieved 8 Jun 2026
  5. [5]European Commission, Corporate sustainability reportingretrieved 8 Jun 2026

This is guidance to help you understand the CSRD and EU sustainability reporting, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.