The document examines a key development for many companies not subject to CSRD requirements: the potential evolution of the VSME into a voluntary European reference standard and the introduction of the so-called ‘value chain cap’, i.e. the limit on the ESG information that companies subject to mandatory reporting may request from companies within their value chain.
The circular may be useful both for companies considering whether to embark on a voluntary reporting process and for those that have already prepared or are preparing a voluntary ESG report and wish to understand how to structure their reporting for the 2026 financial year.
In particular, the document outlines:
- the path from the 2024 VSME to the 2026 draft;
- the practical implications of the value chain cap;
- the main new features of the draft;
- the next expected steps in the European process;
- why the draft can already serve as a useful basis for an initial internal assessment.
We believe that this issue warrants attention even in the absence of a direct reporting obligation, as ESG information is playing an increasingly significant role in relations with customers, banks, investors and business partners.
We remain at your disposal for any clarifications or to explore the potential operational implications for your organisation.
