3 June 2026 — Consultation Response
Accountancy Europe welcomes the opportunity to respond to the European Commission’s (EC) delegated Regulation that sets the value‑chain cap and introduces a voluntary sustainability reporting standard (the “VS”).
Accountancy Europe notes that EFRAG’s voluntary standard for non‑listed micro, small and medium‑sized undertakings (the “VSME”), on which the VS is closely based, was developed with entities of fewer than 250 employees in mind and has not been tested for suitability with larger organisations. We recommend that the assessment of suitability for larger entities be included in the post‑implementation review required under the CSRD.
To reduce the risk of SMEs receiving unnecessary or inconsistent information requests from larger value‑chain partners, we support the categorisation of disclosures as “necessary”, “necessary if applicable”, etc. While this approach was implied in the VSME, explicit labelling of disclosures will help reduce uncertainty for reporting and reporting‑requested entities.
We find that some articles in the delegated Regulation lack clarity and propose targeted drafting amendments to reduce uncertainty inherent in the current wording. Clearer drafting will support consistent application of the value‑chain cap and limit disputes between reporting companies and their suppliers.
We support the removal of disclosures that were present in the VSME but have been removed from the draft amended ESRS. However, we have identified inconsistencies between certain disclosures and definitions in the VS and the draft amended ESRS. We recommend a final consistency check of all disclosures, definitions and cross‑references that are common to the VS and the revised ESRS before final publication, to ensure alignment and avoid contradictory requirements.
We have provided further, detailed comments on certain disclosures in our submission and ask that these be considered during finalisation of the delegated Regulation.
