How to Request CSRD Data from Your Suppliers
If your company reports under the Corporate Sustainability Reporting Directive (CSRD), you need data from your value chain: Scope 3 emissions, resource use, and social information that lives with your suppliers. Since 2026, how you ask for it is regulated. The Omnibus I directive (in force 18 March 2026) put a legal ceiling on what a CSRD reporter may require from smaller business partners, and supplier questionnaires designed before the cap often exceed it.
This guide is for the people who design those requests — procurement, sustainability, and credit teams at in-scope companies. It covers what the value-chain cap allows, what sits outside it, and how to build a request suppliers can actually answer. If you are on the receiving end of a questionnaire instead, start with how to respond to clients’ CSRD data requests.
The Value-Chain Cap: What You May Ask
Under Omnibus I, a CSRD reporter may not require more sustainability information from a business partner with fewer than 1,000 employees than the voluntary SME standard (VSME) defines. The delegated act adopted on 3 July 2026 pins this ceiling to the standard’s Annex II, sets a lower cap for micro-enterprises of 10 or fewer employees, and applies fully to financial years starting 1 January 2027.
In practice this means your standard supplier questionnaire should be built from the VSME disclosure set:
- B3: Energy and greenhouse gas emissions (Scope 1 and 2)
- B6: Water
- B7: Resource use, circular economy, and waste
- B8–B10: Workforce characteristics, health and safety, remuneration and training
- B11: Convictions and fines for corruption and bribery
For a plain-English summary of the change, see The EU Omnibus: What Changed for CSRD; for the supplier’s-eye view of the same boundary, see what large customers can ask suppliers.
What sits outside the cap
The cap is real but has defined carve-outs. You may still request, beyond the VSME set:
- Climate targets and climate risks — VSME Comprehensive disclosures C3 and C4 sit outside the cap, which matters because they are the datapoints banks and large buyers request most
- Information customarily exchanged in your sector (for example, product compliance data in automotive or electronics chains)
- Data required by other EU law — taxonomy, banking regulation, and due-diligence legislation
- Product-level Scope 3 data, where you need it for your own product footprints
The safe design rule: build the core request from VSME, and justify each question that goes beyond it against a carve-out. A questionnaire you cannot map this way is one a supplier may lawfully push back on from FY2027.
Step-by-Step: Designing a Compliant Supplier Request
1. Identify what data you actually need
Start from your own materiality assessment and ESRS datapoints, not from a generic ESG checklist. Focus on the topics where suppliers genuinely carry your impact — typically energy and emissions, waste, and workforce safety. Every question you cut is response-rate gained.
2. Segment suppliers by size
The cap applies to partners below 1,000 employees, with a lower ceiling for micro-enterprises of 10 or fewer. Segment your supplier base accordingly: large suppliers can handle ESRS-extracted templates; smaller ones get the VSME-shaped request; micro-suppliers get the minimum you truly need.
3. Use the VSME structure as your template
Referencing VSME disclosure codes (B3, B7, B8) rather than inventing your own fields means suppliers who already hold a VSME report can answer by attachment, and answers stay comparable across your supplier base. Our CSRD supplier questionnaire template provides a ready structure.
4. Keep it proportionate and answerable
- Offer clear definitions (specify whether energy data should include offices and vehicles)
- Accept estimates or ranges where precise data is unavailable — VSME itself does
- Accept an existing VSME report in place of your form wherever possible
- Set deadlines aligned with your reporting cycle, not procurement’s convenience
Suppliers can now produce a full VSME report at no cost with free tools, including an ESG answer bank, so pointing them at the standard no longer imposes a software bill on them.
5. Store and reuse supplier data
Centralise responses in a register with origin, date, and confidence level. A supplier answer that satisfies this year’s ESRS datapoint will satisfy next year’s too; re-asking annually for static data burns goodwill. See data collection practices for operations teams.
What to Do When Suppliers Cannot Provide Data
Estimates and industry averages are legitimate for value-chain data under the ESRS, provided you document the methodology. Escalate gradually: request, then assist (share the VSME guidance or a free reporting tool), then estimate. Our guide to what to do when suppliers can’t provide CSRD data covers the estimation fallbacks in detail.
Frequently Asked Questions
What should a CSRD supplier data request include?
Who you are, why you are asking, the reporting period, the specific VSME-coded indicators you need, and the format you accept. Attach a template or accept an existing VSME report. Short requests with defined fields consistently outperform broad ESG surveys on response rate and data quality.
Can I still send my old supplier questionnaire?
Check it against the cap first. Questionnaires written before 2026 often mix VSME-level questions with ESRS-depth demands that exceed what you may require from a sub-1,000-employee partner. From financial year 2027 the cap is fully in force, so redesigning now avoids both legal exposure and supplier friction.
Do small suppliers have to answer under CSRD?
Suppliers below the CSRD thresholds have no reporting obligation of their own; they answer your request commercially, not legally. The VSME Standard is the format designed for exactly this exchange, and free tools now generate a complete VSME report, so the cost barrier for your suppliers is largely gone.
Does the cap stop me collecting Scope 3 or climate data?
No. Climate targets (C3) and climate risks (C4) sit outside the cap, as does product-level Scope 3 data. What the cap prevents is demanding ESRS-depth general disclosures from small partners — not the climate data your own E1 reporting depends on.
Key Terms
- CSRD (Corporate Sustainability Reporting Directive): EU law requiring companies with more than 1,000 employees and net turnover above €450 million to report sustainability information, including value-chain data.
- Value-chain cap: The legal limit, introduced by Omnibus I, on the sustainability information a CSRD reporter may require from business partners with fewer than 1,000 employees.
- VSME (Voluntary Sustainability Reporting Standard for SMEs): The EFRAG standard that defines the cap ceiling and structures supplier responses.
- Protected undertakings: Business partners below 1,000 employees whom the cap shields from ESRS-depth data demands.
- Scope 3 Emissions: Indirect emissions occurring in a company’s value chain, including suppliers, logistics, and product use.
Conclusion
Requesting CSRD data from suppliers is no longer a free-form exercise: the value-chain cap defines the ceiling, and the VSME standard defines the shape. Companies that redesign their questionnaires around it get better response rates, comparable data, and no legal exposure — and their suppliers get requests they can answer from a single reusable report.
Start with the supplier questionnaire template, segment your suppliers by size, and let the VSME structure do the standardising for you.