DataSolmu blog
The Voluntary Standard And The Value-Chain Cap: What SME Suppliers Should Prepare
Prepare a reusable SME sustainability answer set and know where customer requests may go beyond it.
Small and medium-sized suppliers have spent years answering sustainability questionnaires that differ from customer to customer. The Voluntary Standard, adopted as Commission Delegated Regulation (EU) 2026/1560 and building on the earlier VSME work, gives those suppliers something they rarely had: a common, published structure for what a smaller company can reasonably report.
It also supports what is often called the value-chain cap. In short, the revised framework is designed to limit how far large in-scope companies should push information requests onto value-chain partners with up to 1,000 employees beyond what the Voluntary Standard covers. The exact boundaries and timing should be read in the legal text and official guidance, but the direction is clear enough to prepare for.
Build One Answer Set, Not Twenty
The most useful step for an SME is to prepare a single, maintained answer set structured around the Voluntary Standard, starting with the Basic Module. Each answer should carry:
- the reporting period and entity it covers;
- the method or source behind any figure;
- the person who owns and updates it; and
- the evidence that would support it if a customer asks.
When a customer questionnaire arrives, the team can map it to that answer set instead of starting again.
Know When A Request Goes Further
Customers may still ask for more detail, sometimes for good reasons such as product-level emissions for CBAM or specific contractual commitments. The point is to notice when a request goes beyond the standard set and to treat that as a conscious decision: is the information available, is it proportionate, and who agrees to provide it?
Recording those decisions protects both sides. The supplier can explain its position consistently, and the customer can see which data comes from the common structure and which is an additional, agreed request.
Use The Digital Template Where It Helps
EFRAG publishes a digital template and XBRL taxonomy for the Voluntary Standard, together with an open-source converter. For suppliers, the practical value is consistency: answers kept in a structured format are easier to reuse, review and share than answers spread across emails and PDFs.
Varmennappi helps suppliers and buyers exchange structured evidence and keep track of who provided what, when and on what basis. It does not provide legal advice, auditor assurance, regulator acceptance or a guarantee of filing compliance. Each organisation remains responsible for its own disclosures and decisions.
Practical Takeaway
Prepare one Voluntary Standard-based answer set with owners and evidence, reuse it across customers, and flag requests that go beyond it as explicit decisions rather than silent extra work.
Source
EUR-Lex: Commission Delegated Regulation (EU) 2026/1560 (Voluntary Standard)