EU carbon rules / Regulations / Voluntary Standard (VS, based on VSME)
Voluntary use by SMEs in supply chains + value chain cap
This regulation applies to:
This Regulation is a delegated regulation; its substantive content (Articles 2 and 3) refers to the entities under Articles 19a and 29a of Directive 2013/34/EU (as amended by Directive (EU) 2026/470); Article 3 applies to financial years beginning on or after 1 January 2027.
The following provisions define its scope:
Article 1(1) — ‘value chain cap’ (definition)
‘value chain cap’ means the upper limit of sustainability information which undertakings subject to Articles 19a and 29a of Directive 2013/34/EU may require from undertakings in their value chain which do not exceed, on their balance sheet date, an average number of 1 000 employees during the preceding financial year.
Article 2(1) — Voluntary reporting
1. Undertakings not subject to mandatory reporting requirements under Articles 19a and 29a of Directive 2013/34/EU may disclose sustainability information on a voluntary basis in accordance with the sustainability reporting standard for voluntary use set out in Annex I to this Regulation (‘voluntary standard’).
Article 3(1) — Value chain cap
1. The voluntary standard shall establish the value chain cap for undertakings subject to mandatory reporting requirements under Articles 19a and 29a of Directive 2013/34/EU.
| Duty | Trigger | Evidence | Timing |
|---|---|---|---|
| May disclose using the voluntary standard Based on VSME, for voluntary use by non-listed SMEs (including a value chain cap). | Non-listed SMEs | Voluntary sustainability disclosure | Voluntary from FY2027 |
Article 1 — value chain cap definition
‘value chain cap’ means the upper limit of sustainability information which undertakings subject to Articles 19a and 29a of Directive 2013/34/EU may require from undertakings in their value chain which do not exceed, on their balance sheet date, an average number of 1 000 employees during the preceding financial year.
Article 2(1) — voluntary reporting
Undertakings not subject to mandatory reporting requirements under Articles 19a and 29a of Directive 2013/34/EU may disclose sustainability information on a voluntary basis in accordance with the sustainability reporting standard for voluntary use set out in Annex I to this Regulation (‘voluntary standard’).
Article 3 — value chain cap
1. The voluntary standard shall establish the value chain cap for undertakings subject to mandatory reporting requirements under Articles 19a and 29a of Directive 2013/34/EU. 2. The value chain cap shall only comprise the datapoints specified in Annex II to this Regulation.