The European Commission published Commission Delegated Regulation (EU) 2026/1560 in the Official Journal on September 21, 2026, making the voluntary sustainability reporting standard legally available to smaller EU undertakings and activating a binding cap on the value-chain data that large CSRD reporters may request from their suppliers. The regulation enters into force on September 24, 2026, while the value-chain cap applies to financial years beginning on or after January 1, 2027.
The act (Delegated Regulation (EU) 2026/1560, EUR-Lex) bundles two instruments that the Omnibus I package foreshadowed: a simplified voluntary standard for undertakings with fewer than 1000 employees, and an Annex II list that fixes the ceiling on the sustainability information mandatory CSRD reporters may demand from their value chain. EFRAG, the Commission's technical adviser, mirrored the publication the same day by flipping its Knowledge Hub caveat to "published in the Official Journal on 21 September 2026" and issuing non-mandatory Voluntary Standard Guidance.
What does the voluntary standard cover, and who can apply it?
The voluntary standard targets the undertakings that Omnibus I (Directive (EU) 2026/470) removed from mandatory CSRD scope: listed SMEs and other EU companies with 1000 employees or fewer that do not cross the new mandatory threshold of more than 1000 employees and more than EUR 450 million net turnover. From September 24, 2026, any such undertaking may apply the standard voluntarily to produce a structured sustainability statement, building on the Basic and Comprehensive modules already prototyped in EFRAG's 2025 VSME Recommendation.
Adoption creates no new reporting duty on its own. Its value is twofold: it lets smaller companies answer the ESG questionnaires that banks, investors and large customers send, using a recognised EU template rather than bespoke spreadsheets, and it aligns with the data points that mandatory reporters are themselves permitted to request.
Which value-chain requests must CSRD reporters cap from FY2027?
The binding element is the value-chain cap. CSRD-mandatory reporters, that is Wave 1 large public-interest entities and the remaining large groups in scope after Omnibus I, may request sustainability information from value-chain partners only within the Annex II data list and only to the extent necessary. From financial years beginning on or after January 1, 2027, any supplier ESG questionnaire exceeding that ceiling is no longer compliant.
This directly affects large reporters such as Siemens, Unilever, TotalEnergies, BNP Paribas and Volkswagen, as well as non-EU groups with EU value chains including Tesla and Toyota. They must recut procurement and supplier-onboarding questionnaires before the FY2027 reporting cycle so that no data point outside Annex II is requested from SMEs and other value-chain partners. The cap is the mechanism that connects the voluntary and mandatory regimes: the information a large reporter may demand is the same information a small reporter may voluntarily disclose.
| Obligation | Who | From when |
|---|---|---|
| Apply the voluntary sustainability standard (optional) | EU undertakings with 1000 employees or fewer | September 24, 2026 |
| Cap value-chain data requests at Annex II | CSRD-mandatory reporters (Wave 1 and remaining large groups) | Financial years beginning on or after January 1, 2027 |
| Implement voluntary datapoints in assurance and software | Statutory auditors, IASPs, sustainability software and consultancies | From the FY2027 reporting cycle |
Who is directly impacted, and what should they do now?
Three groups must act. Sub-1000-employee undertakings should decide whether to adopt the voluntary standard for their next reporting cycle, both to respond to customer and financier ESG requests consistently and to prepare for any later move into mandatory scope. Mandatory CSRD reporters must map current supplier questionnaires against Annex II, strip out requests for data the cap does not permit, and update procurement templates and auditor instructions before FY2027. Accountants, independent assurance services providers and sustainability software vendors must implement the voluntary datapoints so they can collect them, tag them in XBRL under the ESEF taxonomy, and assure them.
What supporting guidance exists, and what comes next?
EFRAG's non-mandatory Voluntary Standard Guidance, published the same day on its Knowledge Hub, walks preparers through the voluntary datapoints and their relationship to the revised ESRS that large reporters use. The revised ESRS themselves were published in the same Official Journal under a separate act, Delegated Regulation (EU) 2026/1563, addressed to mandatory reporters; this article concerns only the voluntary standard and value-chain cap in Regulation 2026/1560. Member State transposition of the Omnibus I scope changes is due by March 19, 2027 for the CSRD side, which will fix the national thresholds that decide who is mandatory and who may volunteer. Continuous, per-jurisdiction real-time monitoring surfaces an Official Journal publication like this the moment it appears, so reporting leads can begin recutting questionnaires before the FY2027 cycle opens.
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Verify whether your undertaking sits below the mandatory threshold (more than 1000 employees and EUR 450 million turnover) and can use the voluntary standard. If you are a mandatory reporter, audit supplier ESG questionnaires against Annex II and schedule the redesign before FY2027. Brief procurement, sustainability and assurance teams on the cap and the voluntary template, and track the March 19, 2027 Omnibus I transposition deadline for the national scope rules. Obsidian follows each national transposition as it lands across the 27 Member States.
