Somewhere in your inbox right now there is an ESG questionnaire you have not opened yet. It might be from a customer’s procurement portal, from your bank’s annual credit review, or from an insurer’s renewal pack. Each one uses a different format, asks slightly different versions of the same questions, and lands with a deadline that has nothing to do with any regulation.
If that describes your week, this piece is for you. It covers why the requests keep multiplying even though the EU just cut its reporting rules back, the legal ceiling on what your customers can now require of you, and how to stop answering every request from scratch.
Update, 30 September 2026: The voluntary standard behind the cap is now EU law. It was published in the Official Journal on 21 September 2026 as Commission Delegated Regulation (EU) 2026/1560, so you can cite it by number. Our follow-up sets out what customers can now require and what they can only ask.
Why the requests keep coming when the regulation went away
On 18 March 2026 the Omnibus I Directive came into force and CSRD shrank dramatically. The threshold is now more than 1,000 employees and more than EUR 450m net turnover, both tests together, which cut the reporting population from roughly 50,000 companies to roughly 5,000 across the EU.
If your company fell out of scope, you might reasonably have expected the questionnaires to slow down. They have not, and the reason is structural. The 5,000 companies still in scope are the largest buyers, banks and insurers in Europe, and their obligations cover their value chains: your emissions, your energy mix, your workforce data, your policies. Banks need supplier and borrower data for financed emissions. Insurers ask at renewal. Procurement teams have embedded ESG scoring in tender processes that are not going to be unwound because a directive changed.
The obligation did not disappear. It moved, from the regulator to your customers. And that changes the nature of your deadline: it is a tender date, a contract renewal, a credit review. Nobody in Brussels set it, and nobody in Brussels will extend it.
The value chain cap: the ceiling on what they can require
Here is the part most suppliers still have not heard. The same Omnibus package that shrank CSRD also gave you a statutory ceiling. If your company has fewer than 1,000 employees, a CSRD-scope customer cannot require you to provide sustainability information beyond what the voluntary VSME standard covers. The European Commission adopted the VSME-based voluntary standard on 3 July 2026, and for CSRD reporters the cap bites from financial year 2027.
We unpacked the legal mechanics in our earlier piece on what the value chain cap lets buyers still ask suppliers, written for the company sending the questionnaire. This post is the other side of the conversation: what to do when you are the one receiving it.
Three things to hold onto. First, the cap limits what a customer can require for their CSRD reporting; it does not stop them asking for more, but they must identify which parts of a request go beyond the cap and tell you that you are entitled to refuse those parts. Second, the cap does not stop you volunteering more if it is commercially worth it. Third, the cap is only useful to you if you actually have a VSME dataset to point at, which is the real work.
How to invoke it without souring the relationship
The cap is a boundary, not a weapon, and the tone that works is helpful-with-a-ceiling. Something like:
“We have fewer than 1,000 employees, so under the Omnibus I value chain cap we maintain our sustainability data against the VSME standard. Our full VSME dataset is attached and covers most of your questionnaire. Could you confirm which of the remaining items you need for purposes other than CSRD reporting, and we will see what we can do?”
You have answered fast, answered most of it, stated the legal position without threatening anyone, and moved the burden of justifying the excess back to the requester. That is a very different conversation from either silence or a flat refusal.
One dataset, many formats
The deeper fix is to stop treating each questionnaire as a document to be written and start treating it as a view of a dataset you already maintain.
The VSME standard is the natural spine for that dataset, because it is now the reference point for what you can be required to provide. Build it once: energy and emissions, workforce basics, policies, certifications, incidents. Attach the evidence to each datapoint, not to a folder, so that every answer you send out carries its source with it. Then each new request, whatever the format, becomes a mapping exercise rather than a writing exercise.
The consistency matters as much as the speed. When five people answer five portals from memory and spreadsheets, the same question eventually gets five slightly different answers, and one of them ends up contradicting the number your company published elsewhere. One maintained dataset is what prevents that.
This is the problem Horizon ESG’s sustainability team workspace is built around: one evidenced dataset, mapped to the frameworks and questionnaire formats you actually get asked for. Nova, the built-in assistant, drafts questionnaire answers from that dataset, with every figure traced to its source and every draft held for your approval before anything leaves the building.
When a customer asks for more than the cap allows
It will happen, usually because the person running the portal has never heard of the cap. A short sequence to work through:
- Check the purpose. The cap governs requests made for CSRD reporting. Data requested for contract qualification, product compliance or the customer’s own risk management sits outside it. Ask which is which; the question itself often shrinks the request.
- Ask them to flag the excess. A CSRD-scope buyer asking beyond the cap is supposed to identify which items exceed it and tell you they are optional. If they have not, asking them to do so is entirely reasonable.
- Decide commercially, not defensively. The cap gives you a right to decline, not a duty. If a strategic customer wants two extra datapoints and you can produce them from your dataset in an hour, volunteer them.
- Counter-offer the dataset. “Here is our complete VSME dataset now; the remaining items would take us six weeks” gives the requester something to bank immediately and usually ends the conversation.
The commercial cost of answering slowly
It is tempting to treat questionnaires as overhead to be minimised. The evidence in front of most sustainability officers points the other way: the requests you are receiving are attached to revenue and to the cost of capital. From January 2027, UK CBAM adds a tax bill to some of them: a UK importer’s charge on steel, aluminium, cement, fertiliser or hydrogen depends on the overseas producer’s emissions data. A tender response that misses the portal deadline is a bid not scored. A slow answer to a bank’s ESG review does not usually lose the loan, but sustainability-linked facilities increasingly tie margin to data quality, and “supplier could not evidence their numbers” is a phrase that shows up in credit files.
Being easy to buy from is the quiet advantage here. The supplier who returns a complete, evidenced, consistent dataset in two days is doing more for renewal season than most marketing budgets.
One dataset, two audiences
A last point worth raising internally: the numbers you send to customers and lenders need to match the numbers your finance team publishes. When the two are produced separately, they eventually diverge, and a customer noticing the difference is the worst possible way to find out. If your CFO is starting to ask assurance-flavoured questions about sustainability data, that is the same problem from the other end; our page for finance teams covers that side.
If your week is currently being eaten by questionnaires, book a short demo and bring your worst one. Answering it from one dataset is the fastest way to see the point.
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