CSRD now reaches fewer companies.
Their suppliers still get asked.
The EU's 2026 Omnibus changes limit CSRD to the largest groups and cap what they can ask of smaller suppliers. For most UK suppliers, the answer is a VSME report.
Team service. CSRD work is a service from our team. VSME, the format suppliers are most often pointed to, is a live lens in the platform.
CSRD at a glance
Team service- What it is
- EU law requiring sustainability reporting under the European Sustainability Reporting Standards (ESRS)
- Who, after the Omnibus
- EU entities or groups with more than 1,000 employees and more than €450m net turnover
- From
- Financial years beginning 1 January 2027
- Suppliers up to 1,000 staff
- Requests capped by the EU's voluntary standard, based on VSME
- UK companies
- Reached mostly as suppliers to EU customers
Source: Directive (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026; Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026.
What CSRD asks, and what reaches you
The directive sets duties for the largest groups. The value-chain cap decides what they can ask of you.
Who it applies to
- EU companies or groups with more than 1,000 employees and more than €450 million net turnover, from financial years beginning 1 January 2027.
- Groups with a non-EU parent: EU net turnover over €450 million in each of the last two financial years, with an EU subsidiary or branch over €200 million net turnover.
- Suppliers of any size can be asked for data by customers in scope.
Source: Directive (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026.
What it asks for
- A double materiality assessment: how the business affects people and the environment, and how sustainability matters affect the business.
- Reporting under ESRS: ESRS 2 for every company in scope, topic standards where the assessment finds a topic material.
- An assurance engagement over the sustainability statement.
Source: Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 (simplified ESRS), applying to financial years beginning on or after 1 January 2027.
What it means for UK suppliers
- Customers in scope should not ask suppliers with up to 1,000 employees for more than VSME covers.
- Customers below the new scope can still ask for what they like commercially.
- The cap is set by the EU's voluntary standard, which is based on EFRAG's VSME.
Source: Directive (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026; Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026.
Dates to know
Omnibus I published
Published
Directive (EU) 2026/470 appeared in the EU's Official Journal, narrowing CSRD scope and adding the value-chain cap.
Source: Official Journal of the EU, L series 2026/470
Voluntary standard and simplified ESRS
Published
The Commission adopted a voluntary standard based on VSME, which sets the value-chain cap, and simplified ESRS. Both were published in the Official Journal on 21 September 2026.
Source: Delegated Regulations (EU) 2026/1560 and 2026/1563
Narrower scope applies
Coming
Financial years beginning on or after this date use the new thresholds, the value-chain cap and the simplified ESRS.
Source: Directive (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026; Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026; Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 (simplified ESRS)
Will a CSRD request reach you, and how big can it be?
Set your customer and your size to see whether the VSME cap applies.
Your EU customer
Your company
EU customer
In CSRD scope
More than 1,000 employees and more than €450m net turnover
Value-chain cap
Applies: VSME limit
Requests to companies with up to 1,000 employees stay within VSME
Your company
Up to 1,000 employees
Answer with VSME, which is a live lens in the platform
What this means
The request is capped at VSME
Your customer is in CSRD scope and you have up to 1,000 employees, so what it asks of you should stay within the voluntary VSME standard.
For orientation only. Source: Directive (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026, and Commission Delegated Regulation (EU) 2026/1560, which sets the value-chain cap from financial years beginning 1 January 2027. Groups with a non-EU parent are in scope if their EU net turnover is over €450 million in each of the last two financial years and they have an EU subsidiary or branch over €200 million.
EU customers are setting their supplier requests now
Customers with financial years starting 1 January 2027 will collect data during 2027, and some of it comes from suppliers.
Exporters
Customers in scope need supplier data
Their reporting covers the value chain, so they will ask suppliers for energy and emissions figures.
Source: Directive (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026
Format
VSME becomes the common answer
The cap points requests at VSME, so one VSME report can answer several customers.
Source: Directive (EU) 2026/470 (Omnibus I), Official Journal, 26 February 2026
Requests
Carbon data requests already arrive
37% of UK firms with 50 to 249 staff, and 20% with 10 to 49 staff, were asked for carbon data in the previous 12 months.
Source: British Business Bank, SMEs and Net Zero 2025, October 2025
How our team helps with a CSRD request
Read the request
We check what your customer asked for and whether the VSME cap applies to you.
Measure what you can
Scope 1 and 2 and your energy use come from your bills in the platform.
Answer in VSME
Where VSME fits, the platform's VSME lens sets out the figures and our team prepares the report with you.
Scope the rest
If your group is in CSRD scope itself, we scope the work with you and say plainly what we can and cannot cover.
What ESGen does for CSRD
CSRD is a team service. The platform supplies the measured figures and the VSME lens.
In the platform
Figures and VSME
Live in the platform today.
- Scope 1 and 2 from bills, with UK government (DESNZ) conversion factors
- The upstream energy share of Scope 3, added automatically
- The VSME lens
- Evidence library and calculation log
VSME report
Environmental metrics
- Energy use2.41 GWh
- Scope 1 and 21,027 tCO₂e
- Evidence attached24 of 24
With our team
CSRD service
Scoped with you, piece by piece.
- Read customer requests and apply the VSME cap
- Prepare VSME reports
- Answer customer questionnaires
- Scope CSRD work for groups that are in scope
Outside what we do
What we do not do
Said plainly, so you can plan around it.
- A CSRD or ESRS lens in the platform
- Assurance of a sustainability statement
- Legal advice on whether CSRD applies to your group
- Guarantee compliance
Learn more about EU reporting
CSRD questions, answered
Could not find your answer? Talk to our team or email contactus@esgen.co.uk.
Sources
Rules change. We checked these sources in September 2026. Confirm your own position with your advisers before you rely on them.
- 1.PwC Viewpoint, Omnibus in brief
- 2.Accountancy Europe, Omnibus explained
- 3.Covington, CSDDD and CSRD Omnibus published in the Official Journal (Feb 2026)
- 4.Directive (EU) 2026/470 of 24 February 2026 (Omnibus I), EUR-Lex
- 5.Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026, voluntary standard and value-chain cap, EUR-Lex
- 6.Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026, simplified ESRS, EUR-Lex
- 7.EFRAG, ESRS and VSME
- 8.British Business Bank, SMEs and Net Zero 2025 (October 2025)
Answer your EU customer with the right report
Send us the request and we will tell you what it needs, and whether VSME covers it.