EU adopts voluntary sustainability standard capping value-chain data demands

The European Commission has adopted a voluntary sustainability reporting standardRegnskapnorge for undertakings outside mandatory reportingRegnskapnorge, and the standard doubles as a cap on what large reporters may demand from smaller undertakings in their value chainRegnskapnorge. The standard is laid down in Delegated Regulation (EU) 2026/1560Regnskapnorge of 3 July 2026, published in the Official Journal on 21 September 2026 and in force in the EU from 24 September 2026.

Undertakings not subject to mandatory reporting under Articles 19a and 29a of Directive 2013/34/EU may disclose sustainability information voluntarily in accordance with the standard set out in Annex I to the regulation. The standard keeps the modular structure of the earlier VSME recommendation: a basic module and a comprehensive module. It contains essential datapoints an undertaking reports when applying the standard, datapoints needed only in specified circumstances, voluntary datapoints, and datapoints considered only for sector-specific information. To stay proportionate, certain datapoints are voluntary for undertakings with 10 employees or fewer even though they are essential for other undertakings applying the standard. Undertakings applying the standard are not obliged to seek assurance for the information they report.

The standard also sets the upper limit — the value chain cap — for sustainability information that undertakings subject to mandatory reporting may require from value-chain undertakingsRegnskapnorge averaging 1,000 employees or fewer during the preceding financial yearEuropa. Only the essential datapoints listed in Annex II to the regulation form the capEuropa, with separate lists for undertakings with more than 10 employees and those with 10 or fewer. Reporting undertakings must request information only insofar as they need it for their own statutory sustainability reportingEuropa, and must ask for less than the standard specifies when they do not need it all. The cap covers only information gathering for sustainability reporting under national law transposing Directive 2013/34/EUEuropa; it does not affect information requests needed for other Union or national law obligations. Financial institutions and other finance actors are still encouraged to limit sustainability-information requests beyond statutory reporting to the standard as far as possible.

In Norway the voluntary standard is to be implemented in a regulationRegnskapnorge, with the legal basis proposed in Prop. 106 L (2025-2026), which the Storting has not yet considered. No date for the Norwegian regulation has been set. Shielded undertakings under the government bill (skjermede foretak) with up to 1,000 årsverk in a reporting undertaking's value chainRegnskapnorge may refuse to provide more information than follows from the regulationRegnskapnorge. Banks and others may still request information for other purposes, such as credit assessment. Undertakings can already use the standard now.

The same day also brought revised mandatory standards: Delegated Regulation (EU) 2026/1563 replaces the annexes of Delegated Regulation (EU) 2023/2772 with simplified European sustainability reporting standards (ESRS)Europa. Mandatory reporting applies, after the Omnibus I simplifications, only to the very largest undertakingsRegnskapnorge; the government proposes the Norwegian threshold at over 1,000 årsverk and over 5 billion kroner in sales revenueRegnskapnorge. The revised standards apply to financial years beginning on or after 1 January 2027Europa. For financial years starting between 1 January and 31 December 2026, undertakings in scope may apply either the previous standards or the new ones, or the previous standards with listed reliefs such as the top-down double materiality approach and value-chain limitationEuropa, and must state which version they apply. The Finance Ministry aims to amend the Norwegian reporting-standards regulation so Norwegian undertakings can also use the revised ESRS for the 2026 financial year.

Legal basis: Delegated Regulation (EU) 2026/1560 on the voluntary standard and value-chain cap; Delegated Regulation (EU) 2026/1563 on the revised ESRS.