EU Omnibus: can you decline a sustainability questionnaire from a client?
Plenty of SME suppliers have, by now, received a long, company-specific sustainability questionnaire from a client — sometimes dozens of pages, with questions that seem to have little to do with their own business. The EU Omnibus simplification package addresses this problem explicitly, through a new concept: the "value chain cap".
What is the EU Omnibus simplification?
The Omnibus is a package of legislative changes from the European Commission that simplifies the CSRD and related regulation, after companies — large and small — flagged the reporting burden as excessive. Part of this package is an explicit protection for smaller value-chain partners against excessive data requests from their large, CSRD-obligated clients.
The "value chain cap": a limit on what can be asked
The value chain cap states that a CSRD-obligated company may, in principle, not ask suppliers with fewer than 1,000 employees for more information than what's covered by the VSME standard. If a client still asks for additional, non-VSME information, you as a smaller supplier have the right to decline without breaching any legal obligation.
Does this mean you don't have to supply anything?
No — and that nuance matters. The value chain cap gives you the right to decline requests beyond VSME, not the right to supply nothing at all. Your client still needs the data for their own scope 3 reporting, and the commercial relationship doesn't change just because a legal ceiling now exists. In practice, it's simplest for both parties to just stay within the VSME standard: your client gets exactly the data they need, and you never have to supply more than the legal maximum allows.
Practical advice for suppliers
If you receive a questionnaire that clearly goes beyond the VSME Basic Module (for example, detailed audits or company-specific KPIs outside B1–B7), you're entitled to question it and, if you wish, refer to the value chain cap. If you instead proactively build a VSME profile — for example through verified.supply — you avoid the discussion entirely: you supply exactly the legal maximum that can be asked of you, in a format every client can use right away.
Frequently asked questions
- What is the "value chain cap" under the EU Omnibus?
- The value chain cap is a rule stating that CSRD-obligated companies may not ask suppliers with fewer than 1,000 employees for more sustainability information than what's covered by the VSME standard.
- Can I decline a sustainability questionnaire from a client as an SME?
- You have the right to decline additional questions that go beyond the VSME Basic Module, if you have fewer than 1,000 employees. Questions within the VSME standard are not covered by this right to decline.
- Does the value chain cap mean I don't need to supply any data at all?
- No. It gives you the right to decline requests beyond the VSME standard, not the right to supply nothing. Your client still needs the VSME data for their own scope 3 reporting.
- Is it smarter to just build a VSME profile instead of declining requests?
- In most cases, yes. A VSME profile provides exactly the data that is legally the maximum that can be requested, in a standard format every client can use right away — avoiding disputes and keeping the commercial relationship smooth.
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