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What the changes mean for smaller firms

CSRD, Omnibus, and SMEs: the honest picture

The CSRD scope has moved, and the Omnibus package changed who reports and when. For a smaller company the practical question is simpler than the headlines: what will a bank still ask you for, and how much can they demand?

The Corporate Sustainability Reporting Directive (CSRD) makes large companies report detailed sustainability data. The Omnibus simplification package narrowed and rephased parts of that, which is why the news has been noisy. But the effect on a small supplier is not really about whether you are in CSRD scope. You almost certainly are not. It is about the requests that flow down to you from those who are.

The request still comes down the chain

Banks and large corporates that report under CSRD need sustainability data from the companies they lend to and buy from. That demand does not disappear because the rules were simplified. If anything it concentrates: fewer, larger reporters asking their value chain for the numbers they need.

The value chain cap is your protection

Here is the part that matters most for an SME. A large company cannot force a smaller supplier or borrower to hand over more sustainability data than the VSME voluntary standard asks for. That is the value chain cap, and it applies to companies with 1000 employees or fewer. VSME is the ceiling on what they can demand from you, not a floor you have to exceed.

If a questionnaire asks a fifty person firm for far more than VSME covers, the value chain cap says you are not obliged to provide it.

Why VSME is still the answer

Because the cap is defined by VSME, producing a VSME report is both the maximum anyone can ask of you and the shape they will recognise. You answer once, in the format banks expect, and you can point to the cap if a request overreaches. A delegated act expected in 2026 is set to give VSME firmer standing, which only strengthens the case for reporting in that shape now.

What to do

Do not wait for the CSRD debate to settle. Produce a VSME Basic Module report, keep it ready, and reuse it for every bank and customer request. That turns an uncertain regulatory backdrop into one concrete document you control.

Common questions

Did the Omnibus package remove sustainability requests for SMEs?

No. It reshaped who formally reports under CSRD, but banks and large customers still ask their value chain for data. The value chain cap limits how much they can ask of smaller firms to the VSME standard.

What is the value chain cap exactly?

A limit that stops CSRD reporters from demanding more sustainability data than VSME covers from companies with 1000 employees or fewer.

Turn the uncertainty into one report

Produce a VSME report you control and reuse for every request, protected by the value chain cap. First report free.

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