A sustainability report is increasingly becoming a practical tool for companies to respond to questions from clients, banks, investors and supply chain partners. Although mandatory sustainability reporting under the CSRD does not apply to all companies, ESG information requests are already reaching small and medium-sized enterprises as well.

A voluntary sustainability reporting standard is becoming increasingly relevant for companies that fall outside the scope of mandatory CSRD reporting. On 6 May 2026, the European Commission published a draft delegated act on a voluntary sustainability reporting standard for companies with up to 1,000 employees. This standard is based on the voluntary sustainability reporting standard for SMEs, also known as VSME.

What is the voluntary sustainability reporting standard?

The voluntary sustainability reporting standard is intended for companies that are not required to prepare a sustainability report under the CSRD, but want or need to provide ESG information to their business partners.

This may be relevant if the company:

• Works with large clients that fall within the scope of the CSRD ;
• Participates in supply chains;
• Receives ESG questionnaires from banks, buyers or partners;
• Wants to assess its impact on the environment, employees, governance and the community in a structured way;
• Plans to prepare a sustainability report but is not yet ready to fully apply the ESRS.

How is this related to the CSRD?

CSRD is the Corporate Sustainability Reporting Directive, under which certain companies are required to prepare sustainability reports. Companies within the scope of the CSRD , must report in accordance with the European Sustainability Reporting Standards, abbreviated ESRS.

However, even if your company does not fall directly within the scope of CSRD requirements, it may be part of a larger company’s value chain. In such cases, you may be asked to provide information on energy consumption, GHG emissions, employees, suppliers, business ethics, governance or other ESG aspects.

The voluntary sustainability standard helps clarify what sustainability information can reasonably be requested from small and medium-sized companies.

What is the “value chain cap”?

One of the most important elements of the new voluntary standard is the “value chain cap” principle.

This means that companies within the scope of the CSRD , when collecting ESG information from supply chain partners, will not be able to request more information from companies with up to 1,000 employees than is set out in the voluntary standard. For small and medium-sized companies, this provides clearer boundaries. They can prepare a core set of ESG / sustainability data and know that this will serve as a basis for responding to many supply chain requests.

How do VSME and the new Voluntary Standard differ?

The new voluntary sustainability reporting standard is being developed based on the voluntary sustainability reporting standard for SMEs - VSMEThe core structure remains largely unchanged, but some VSME disclosures are being removed, while others are being clarified or narrowed.

What should a company do now?

If your company is already receiving ESG information requests, or is likely to receive them in the near future, it is worth starting with several practical steps.

First, assess what sustainability information the company already has. In many cases, part of the data already exists within finance, HR, quality, environmental or procurement processes.

Second, compare the available information with the structure of VSME or the Voluntary Standard. This helps identify what information is missing and which indicators should not be collected unnecessarily.

Third, it is useful to prepare a sustainability report, or at least an ESG information set, that can be used when responding to clients, banks and supply chain partners.

We invite you to discuss how sustainability reporting can become not only a compliance process, but also a tool that creates value for your business.

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