If you are an SME supplying a company that reports under CSRD, there is a limit on the sustainability data they can require from you. The VSME standard sets a cap on information requests that CSRD-reporting companies may make of SMEs in their upstream and downstream value chain.
This matters because the alternative is unbounded. Without a cap, every large customer designs its own questionnaire, and a supplier with fifteen major customers answers fifteen different sets of questions annually, none reusable.
What the cap does
The cap defines the reasonable ceiling of what a large company may require from an SME in its value chain. Report to VSME and you have met the standard the cap is built around. Requests reaching beyond it are requests you have a principled basis to push back on.
Two things this is not.
It is not a legal shield. Your customer can still ask. You can still refuse. Neither of you is breaking a law. What the cap changes is whose position is reasonable, and that matters when the conversation escalates.
It is not a reason to report nothing. The cap protects you from unbounded demands. It does not protect you from a customer who needs value chain data and will find a supplier who provides it. Reporting to the standard is the point; the cap is what stops the standard from being a floor that keeps rising.
What sits inside the cap
Broadly, the disclosures VSME itself defines: general business information, environmental data including energy and greenhouse gas emissions, social data covering workforce and health and safety, and governance and business conduct.
If a customer asks for something in this set, the answer is to report it, ideally once, in VSME format, reusable across every customer who asks.
What typically sits outside
These are the requests worth examining rather than reflexively answering.
Bespoke formats for the same data. A customer wants your emissions figure in their proprietary spreadsheet with their category structure. The data is inside the cap; the format demand is overhead. Offer the VSME report. Most customers accept it, because their own reporting system has to ingest supplier data in some standard form anyway.
Facility-level detail where corporate-level is the standard. A request to break emissions down by site, product line, or the specific goods sold to that customer, when the standard calls for organisational reporting.
Primary data where estimation is accepted. Demands for measured supplier-specific figures on categories the standard permits you to estimate. Producing primary data here can mean months of work for a marginal accuracy gain.
Your own suppliers' data. Requests that you collect and pass on data from your upstream suppliers, effectively deputising you to run your customer's value chain exercise.
Audit and assurance you have not committed to. Third-party verification of SME data, where the standard does not require it.
Anything unrelated to their reporting obligation. Questions that exist because the questionnaire was designed once and never pruned. This is more common than it sounds.
How to decline without damaging the relationship
The mistake is treating this as a compliance argument. It is a commercial conversation, and it goes better when you lead with what you are providing.
Lead with the report. "Here is our VSME report, which covers emissions, energy, workforce and governance." Starting from a substantive answer changes the tone entirely from starting with a refusal.
Name the standard. "We report to VSME, the EU standard for SME sustainability reporting in the value chain." This signals you have done real work and understand the framework, which is more persuasive than saying a request is burdensome.
Be specific about what you are declining and why. "We can provide organisational Scope 1 and 2. Site-level breakdown is not something we produce, and VSME reports at organisational level." Precision reads as competence.
Offer a path if it matters to them. "If facility-level data is essential, we can scope that as a project." Some customers will pay. Most will discover it was a nice-to-have.
Escalate to procurement, not sustainability. The questionnaire usually originates with a sustainability team working from a template. Procurement understands supplier burden and contract value, and is often the more productive conversation.
When to just answer
The cap is a tool, not a principle to defend. Answer without argument when:
- The request is inside the cap. Refusing here is losing goodwill for nothing.
- The customer is a major share of your revenue and the ask is modest.
- The data is genuinely easy for you to produce.
- It is a tender, and the data is scored. Bid requirements are not the place to litigate scope.
Save the pushback for requests that are genuinely disproportionate, and you will find it lands better when you use it.
The position that makes this work
All of this depends on having a VSME report to point to. Declining requests while providing nothing is not a defensible position; it is just refusing.
The strongest position for an SME is a current VSME report with real numbers behind it, particularly the emissions disclosure, which is the one customers press on hardest. That needs a carbon footprint covering Scope 1 and 2 at minimum, and Scope 3 where your customers' own reporting depends on it.
The efficiency argument is straightforward. Calculate once, report once, reuse across every customer who asks. That is the whole design intent of the standard, and it is why keeping the calculation on a consistent platform year over year matters more than the first year's number.
The practical read
Suppliers who report to VSME spend less time on questionnaires than suppliers who answer everything ad hoc, and considerably less than suppliers who answer nothing and then negotiate under pressure during a tender.
The cap exists to make that possible. Using it requires having reported in the first place.
Start with what VSME covers, or talk to us.
Sources: EFRAG VSME standard, European Commission Omnibus I package.
