The CSRD Value Chain Cap: What You Can Still Ask Suppliers for Carbon Data From 2027

Why now: The revised ESRS enter into force on 10 November 2026, and from financial years beginning on or after 1 January 2027, CSRD reporters can no longer require suppliers with 1,000 employees or fewer to provide more than a short list of datapoints for their sustainability reporting.

Your supplier questionnaire probably asks for Scope 1, 2 and 3, reduction targets and a product carbon footprint (PCF) for every SKU you buy. It goes to large chemical producers and family-owned packaging converters alike.

From January 2027, sending that same questionnaire to a 300-person supplier, and insisting on every answer for your CSRD report, stops being an option. The question for sustainability and procurement teams is no longer "how do we get more data from everyone?" but "which data can we still require, from whom, and on what basis?"

This guide answers that question and shows how to keep your Scope 3 inventory improving under the cap.

What is the CSRD value chain cap?

The value chain cap is a ceiling on the sustainability information a CSRD reporter may require from smaller companies in its value chain for its own reporting. It is set by Commission Delegated Regulation (EU) 2026/1560, the Voluntary Standard, which applies the cap from financial years beginning on or after 1 January 2027.

The key facts:

• Who is protected: value chain undertakings with an average of 1,000 employees or fewer in the preceding financial year.
• What you may require: nothing beyond the essential datapoints listed in Annex II of the Voluntary Standard.
• What it covers: only information gathered for your own CSRD reporting. It does not restrict requests needed to comply with other EU or national law.
• Where it comes from: the Omnibus I Directive, Directive (EU) 2026/470, gives protected undertakings the right to decline information exceeding the voluntary standards when it is requested for sustainability reporting. Member States must transpose it by 19 March 2027.

The cap arrives with the revised ESRS, Commission Delegated Regulation (EU) 2026/1563, published in the Official Journal on 21 September 2026 and mandatory for financial years beginning on or after 1 January 2027. EFRAG's revision behind them proposed cutting mandatory datapoints by 61%. For the wider Omnibus picture, see our analysis of what Omnibus I means for your CSRD and CSDDD plan.

Note the asymmetry: since Omnibus I, a company is only in CSRD scope if it exceeds both EUR 450 million net turnover and 1,000 employees. Many of your mid-sized suppliers have just left CSRD scope and are now also protected by the cap.

Which carbon datapoints can you still request from capped suppliers?

For suppliers with more than 10 employees, practitioner summaries of Annex II list total energy consumption and estimated gross Scope 1 and location-based Scope 2 emissions among the capped datapoints. For suppliers with 10 or fewer employees, the Annex II list contains no environmental datapoints at all.

What is not in the list matters more for carbon teams:

• Scope 3: not among the Annex II datapoints according to the same summary. Under the Voluntary Standard, Scope 3 disclosure is voluntary and only envisaged where relevant.
• Reduction targets: GHG reduction targets sit in the comprehensive module of the Voluntary Standard (module C3), not among the Annex II datapoints listed in practitioner summaries.
• Product carbon footprints: PCFs are not a Voluntary Standard datapoint. If you require one from a capped supplier for your CSRD report, treat it as above the cap.

Two procedural rules apply to anything above the cap. If you ask for it, you must disclose which additional information you are requesting and that the supplier may refuse. And the cap is a ceiling, not an entitlement to the whole list: ask only for what your reporting needs. Summaries are not the legal text: check the Annex II rows in the Official Journal before rebuilding your questionnaire.

Does the cap stop customer PCF requests, PACT exchanges and CBAM data?

Not automatically. The cap targets requests made for the requester's CSRD reporting; other purposes follow their own rules. But the line between "for my CSRD report" and "for my business" is not always clean, so this is where a legal review can come in handy.

What the texts say:

• Other law: the cap does not affect requests deriving from other national or Union legislation. CBAM is the obvious case: under Regulation (EU) 2023/956, the definitive period started on 1 January 2026, with actual emissions verified by an accredited verifier. Embedded-emissions data for CBAM goods therefore rests on a separate legal basis.
• Voluntary sharing: the Commission's explanatory memorandum states that the cap "does not prohibit the sharing, on a voluntary basis, of information that is commonly shared among undertakings in a given sector". In chemicals and CPG, PCF exchange under PACT or Together for Sustainability (TfS) is very much a practice, but no text names them.
• Contracts: the same memorandum says the cap does not affect contractual obligations to provide information that does not exceed the information specified in the voluntary standard. Contract clauses demanding more than the cap for CSRD purposes are therefore risky.

Here is a working map. It is a starting point for your legal team but we recommend seeking out actual legal advice:

The practical consequence: PCF requests driven by commercial demand, not by CSRD, will carry more of the weight. Ask smaller suppliers in a way that is clearly voluntary, or clearly grounded in something other than your sustainability statement.

How should you redesign your supplier data program for the cap?

Split your supplier base by size and by the legal basis of each question, then fill the gaps you can no longer close by mandate with estimates and voluntary exchange. Seven steps:

1. Segment suppliers by headcount. Add an "average employees, preceding financial year" field to supplier master data and ask suppliers to self-declare it.
2. Rank by emissions, not by spend alone. One global truck and bus manufacturer, with a network of 50,000 suppliers, baselined 100% of its Scope 3.1 emissions at part and commodity level with CO2 AI, which is what lets a team see which suppliers move the number.
3. Tag every question with a purpose and a basis. CSRD, CBAM, due diligence, product claim, SBTi supplier target or commercial. One questionnaire, several legal bases.
4. Build two questionnaires. A full version for large suppliers. A capped version for suppliers with 1,000 or fewer employees, limited to Annex II, with any additional questions clearly marked optional and the right to decline stated.
5. Fill gaps with transparent estimates. Use spend-based or average-data methods, and enrich them with public supplier information such as sustainability reports and climate target commitments.
6. Make voluntary PCF sharing worth it (next section).
7. Review contracts and supplier codes of conduct with legal counsel, so no clause requires above-cap information for CSRD purposes.

How do you make voluntary PCF sharing attractive to smaller suppliers?

Lower their effort and raise their return. A supplier that can reuse one PCF across many customers, at no cost, has a reason to share it without being forced.

• Ask once, in a standard format. A PACT-aligned PCF can serve every customer. Mind the methodology version, and read how PACT V3 affects PCF recalculations before you compare numbers.
• Give them free tooling. Our Supplier Accelerator, SPARC, is a community for suppliers across CPG, automotive and chemical companies, to access tooling, experts and hands-on support. If you want to be part of the program or want to invite your suppliers, get in touch with our team.
• Tie data to commercial upside. Carbon criteria in tenders reward suppliers who disclose. Our guide to carbon criteria in procurement shows how to score data quality without punishing honest suppliers.
• Share something back. Benchmarks or joint reduction projects make the exchange two-way. The more context and actionable feedback you can give to your suppliers on the importance of accurate PCFs, the more motivated they will be to share that data with you.

On the buyer side, the CO2 AI Supplier Engagement Hub lets you send tailored data requests to hundreds of suppliers at once, receive primary emissions data, PCFs and LCAs in one place, and rank suppliers by emissions exposure, data quality and reduction potential. That ranking is what tells you where a voluntary PCF is worth chasing and where an estimate will do.