The EU Voluntary Standard gives smaller companies a common structure for answering sustainability questions from customers, banks and investors. It builds on the VSME standard and also defines the information covered by the CSRD value chain cap.
Delegated Regulation (EU) 2026/1560 entered into force on 24 September 2026. The value chain cap applies from financial years starting on or after 1 January 2027.
This guide explains what the Voluntary Standard covers, how the value chain cap works and what to check before you answer an ESG questionnaire.
What is the EU Voluntary Standard?
The EU Voluntary Standard is the sustainability reporting standard for companies not subject to mandatory sustainability reporting under the Corporate Sustainability Reporting Directive (CSRD). It is set out in Annex I of Delegated Regulation (EU) 2026/1560.
It builds on the VSME standard published by EFRAG in December 2024 and the Commission’s VSME recommendation of 2025. The two are close, but not identical. When a customer refers to the value chain cap, the reference point is the Voluntary Standard.
As an EU regulation, it applies directly in all Member States. The obligations of companies that report under the CSRD still depend on national law.
Who can use the Voluntary Standard?
The standard is meant for companies outside the CSRD with up to 1,000 employees, including micro-companies and the self-employed.
The standard does not create a mandatory reporting obligation. It gives you a common structure for sharing sustainability information with business partners. You can decide whether to publish your report or share it only with specific partners. The Voluntary Standard itself does not require assurance.
What does the Voluntary Standard include?
The standard has two modules.
| Module | What it covers | Who it is for |
| Basic Module (B1 to B11) | General information, sustainability practices and policies, energy and greenhouse gas emissions, pollution, biodiversity, water, resource use and waste, workforce, health and safety, pay and training, corruption and bribery | The starting point for every company and the target level for micro-companies |
| Comprehensive Module (C1 to C9) | Business model and strategy, climate targets and transition plans, climate risks, more workforce data, human rights policies and incidents, revenue from certain sectors, gender diversity in the governance body | Companies whose banks, investors or large customers ask for more |
Complete the Basic Module first. You may then add selected disclosures from the Comprehensive Module or apply that module in full. If you add selected disclosures, identify them clearly without claiming compliance with the full Comprehensive Module.
Completing a module does not mean reporting every datapoint regardless of whether it applies. Follow the conditions and reliefs in the standard. For companies with 10 employees or fewer, some disclosures that are required for larger companies are voluntary.
What changed from VSME to the Voluntary Standard?
The Commission kept the structure and most of the content of VSME. The main changes are practical:
- Clear labels for each datapoint. Every datapoint is marked as necessary, necessary if applicable, voluntary, or relevant only for sector information.
- More relief for the smallest companies. Several demanding disclosures are voluntary for companies with 10 employees or fewer.
- A legal limit on data requests. Annex II lists exactly which datapoints fall under the value chain cap.
- Better alignment with the revised ESRS. The standard improves alignment with the standards used by larger reporting companies.
Read our guide to the revised ESRS 2026
How does the CSRD value chain cap work?
From financial years starting on or after 1 January 2027, the value chain cap protects companies with an average of no more than 1,000 employees in the previous financial year.
Companies reporting under the CSRD cannot require these suppliers to provide more for their CSRD reporting than the datapoints listed in Annex II. There are two levels: one for companies with 10 employees or fewer and one for companies with 11 to 1,000 employees.
In practice:
- The cap does not create a duty to answer. It does not oblige a supplier to provide information, even where the requested datapoint is within Annex II.
- A customer can still ask for more, but cannot require it for CSRD reporting.
- Extra requests must be marked. The customer must show which questions go beyond the cap and tell you that you have a legal right to decline them.
- The cap list is not the same as the Basic Module. Annex II sets its own list. Check each question against Annex II, not against the module you report.
- The cap covers CSRD reporting only. Requests made for other legal purposes are assessed separately.
- Banks are encouraged to follow a similar limit. For requests outside CSRD reporting, financial institutions are encouraged to limit what they ask from companies with up to 1,000 employees to Annex I. This is guidance, not a binding rule.
Read our guide to CSRD scope after Omnibus I
ESG questionnaires: what to check before answering
Before you fill in a questionnaire, check four things:
- Purpose. Is the information for the customer’s CSRD report, a bank loan, a tender or another legal requirement? The value chain cap applies only to CSRD reporting.
- Period. Which financial year does the request cover?
- What you already have. Which answers can you take from your Basic Module data or earlier replies? State the period and version of the data you use, so figures from different years do not get mixed.
- What goes beyond the cap. For CSRD requests, check the exact question and the level of detail against Annex II, rather than treating a whole ESG topic as inside or outside the cap.
An illustrative example. A manufacturer with 120 employees receives a questionnaire from a large customer that reports under the CSRD. It asks for energy use, Scope 1 and Scope 2 emissions, headcount and workplace accidents. It also asks for a detailed Scope 3 emissions inventory. The first questions are typical Basic Module data. If the detailed Scope 3 inventory is not in the Annex II list and the customer needs it for CSRD reporting, the customer should mark it as additional information, and the supplier has the right to decline it or can choose to share it.
Using the Voluntary Standard does not guarantee that every customer will accept your report instead of its own questionnaire. It gives you a common basis for preparing and reusing answers.
How to get started with the EU Voluntary Standard
- Check your position. Confirm your average number of employees and that you are outside the CSRD scope.
- Start with the Basic Module. Add disclosures from the Comprehensive Module when your banks, investors or customers need them.
- Collect the core data. Common starting points include energy use, Scope 1 and Scope 2 emissions, waste, headcount, health and safety, and pay.
- Use the free tools. In November 2026, EFRAG released an updated Voluntary Standard Digital Template in Excel and a converter that produces an Inline XBRL report.
- Keep owners and evidence. Assign an owner to each figure and keep the source with it, so you can update and reuse approved answers.
Free template or software?
For a single company with a straightforward reporting process, EFRAG’s free template may be sufficient.
It gets harder when many people provide data, when you have several sites or entities, when several customers send different questionnaires, or when you need to show where each figure came from. Then the problem is coordination: versions, deadlines and evidence.
Where ESG Platform fits
ESG Platform keeps sustainability data organized in one workflow. Each datapoint has an owner, a deadline and a status, and the evidence stays with the data. You can reuse approved information where it fits and update it when it changes. Data is hosted in the EU.
Smaller companies use it to prepare answers for customers and banks. Larger companies and consultants use it to collect supplier data within the value chain cap.
Talk to our experts about your sustainability data.
VSME standard: frequently asked questions
Is the EU Voluntary Standard mandatory?
No. The standard does not create a reporting obligation. The value chain cap in the same regulation is binding for companies that report under the CSRD.
Is VSME the same as the Voluntary Standard?
No. The Voluntary Standard is based on VSME but includes changes, such as datapoint labels, extra relief for companies with 10 employees or fewer and the Annex II cap list. Use the Voluntary Standard as your reference.
Do I need a double materiality assessment?
The Voluntary Standard does not ask for an ESRS-style double materiality assessment. Some disclosures apply only where they are relevant to your business.
Can a customer ask me for more data than the cap allows?
Yes, they can ask. For their CSRD reporting, they must mark the questions that go beyond Annex II and tell you that you can decline. You may still choose to share more.
Will customers accept a Voluntary Standard report instead of their questionnaire?
Not always. The standard gives you a common basis, but each customer decides what it needs. Within CSRD reporting, the value chain cap limits what it can require.
Where can I find a template?
EFRAG publishes a free Voluntary Standard Digital Template and an Inline XBRL converter. The guidance is on the EFRAG Knowledge Hub.
Sources
- Commission Delegated Regulation (EU) 2026/1560: Voluntary Standard (Annex I) and value chain cap (Annex II).
- Directive (EU) 2026/470: Omnibus I and the basis for the value chain cap.
- EFRAG Knowledge Hub: Voluntary Standard: text of the standard and guidance.
- European Commission: questions and answers on the value chain cap: right to decline and marking of additional requests.
- EFRAG: VS Digital Template and XBRL taxonomy.