The value chain cap: what it protects, and what it does NOT (EcoVadis, Scope 3 and banks stay outside)
*Update 5 August 2026:* The value chain cap is no longer a draft. Since 3 July 2026 it is legally anchored, when the European Commission adopted VS 2026…
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Update 05.08.2026: The Value Chain Cap is no longer a draft as of July 3, 2026, but is legally anchored – the EU Commission adopted the VS 2026 as a delegated act on this day.
Hardly any term is causing as much confusion right now as the "Value Chain Cap". Many suppliers hope it will completely relieve them of the data pressure from their large corporate customers. The honest answer: It closes exactly one channel – and leaves most others open.
What the Value Chain Cap specifically regulates
The Value Chain Cap states: A large enterprise subject to CSRD reporting requirements may not request more sustainability data from a supplier with up to 1,000 employees than what is contained in the VS standard (formerly VSME) – but only if the request serves the large customer's own statutory CSRD reporting.
The Cap was agreed upon as a principle within the framework of the EU Omnibus Package and, with the adoption of the VS 2026 by the EU Commission on July 3, 2026, is legally anchored as a delegated act – no longer just a political project. The modular structure of the previous VSME remains largely intact (around 180 out of 200 data points), with new additions including a separate, leaner regulation for micro-enterprises with fewer than 10 employees.
What is NOT covered by the Cap
This is the crucial part that is missing in most explanations. Expressly not covered are:
Channel | Covered by the Cap? |
|---|---|
Purely CSRD-related reporting request from a large customer to you | ✅ Yes, capped to VS scope |
EcoVadis and other ESG ratings | ❌ No |
Contractual/voluntary procurement questionnaires | ❌ No |
Bank inquiries | ❌ No |
Requirements from supply chain due diligence obligations (CSDDD/LkSG) | ❌ No |
EU Taxonomy inquiries | ❌ No |
"Industry standard" exchanged data | ❌ No |
Scope 3 and certain climate data (C3/C4) | ❌ No |
In short: The Cap covers exactly one type of request – that which directly serves the statutory CSRD reporting of a large corporate customer. EcoVadis, voluntary questionnaires, bank inquiries, and Scope 3 data remain completely unaffected.
The schedule at a glance
March 2026: Omnibus I Directive enters into force, new CSRD thresholds (>1,000 employees and >€450 million in turnover, cumulative) apply.
Until June 3, 2026: Public consultation by the EU Commission on revised ESRS and the VS.
May 6, 2026: Draft of the VS 2026 published.
July 3, 2026 – already completed: The EU Commission adopts the VS 2026 as a delegated act. The Value Chain Cap is thus legally anchored.
Next: The legal act goes through the regular scrutiny process of Parliament and Council before formally entering into force – it is worth checking the exact application date before publication in the EU Official Journal, as it can still shift.
The Cap is therefore no longer just a politically agreed principle, but an adopted legal act – much more binding than in early summer 2026. However, this does not change the core message of this article: It still only caps a single channel.
An example for context
A supplier with 300 employees supplies a large corporate group subject to CSRD. In the same year, the group requests: (1) data for its own CSRD report, (2) an EcoVadis assessment as a procurement criterion, (3) Scope 3 data for its carbon footprint. After applying the Cap from 2027, only request (1) would be capped to the VS scope. Requests (2) and (3) would remain completely unaffected – the supplier would still have to deliver the full scope required by EcoVadis or the corporate group's Scope 3 methodology.
Why the message "the Cap protects you" is misleading
The Cap plugs a single hole – the major channels through which most data pressure actually arises remain open. Anyone relying on the Cap to flatly reject data requests will still stand there without a data basis at the next EcoVadis assessment or bank inquiry. The more realistic interpretation: The Cap is a selective relief, not a general shield – and that is exactly why a solid, independent data basis remains necessary.
What this means for your practice
Instead of checking whether a specific request "falls under the Cap", it is worth asking the more pragmatic question: Where does the request come from, and what data does it actually need? In most cases – EcoVadis, voluntary questionnaire, bank, Scope 3 – the Cap does not help anyway, and the only sensible preparation is a structured, reusable data basis. (How to build it: Is your customer suddenly demanding sustainability data?.)
How strait prepares you independently of the Cap
strait continuously records your energy and operational data via IoT sensors – regardless of which channel the next request comes through. Whether it is EcoVadis, a bank meeting, a voluntary customer questionnaire, or a VS report: The data basis is the same, only the preparation differs. This makes you independent of the outcome of the Cap discussion.
Ready for all channels at the same time? Download the free "Capped vs. Not Capped" cheat sheet – one page that shows what the Cap really covers.
Ready for all channels – with or without Cap?
Download the "Capped vs. Not Capped" cheat sheet – or book a demo.
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