Voluntary sustainability for SMEs in value chains: what changes in 2026

Key data

If you are a supplier to a large European company, you already face ESG pressure even though you are not obliged to report on sustainability. The Commission Delegated Regulation (EU) 2026/1560 solves exactly that problem: it creates a simplified, voluntary disclosure standard adapted to the capacity of SMEs and medium-sized enterprises that are part of value chains of large groups.

The standard completes Directive 2013/34/EU (the basis of the CSRD) and comes into force on 3 July 2026, with publication in the EU Official Journal on 21 September 2026.

What does this regulation establish?

The regulation creates a sustainability information disclosure framework specifically designed for companies that fall below the mandatory CSRD threshold but operate as suppliers or business partners of large corporations that are obliged to report.

The key points of the standard are:

• Voluntary nature: no SME is obliged to adopt it. It is a tool, not an obligation.
• Designed for the value chain: it directly responds to ESG data requests that large corporations must collect from their suppliers to complete their own CSRD reports.
• Simplification compared to full ESRS: the ESRS standards (European Sustainability Reporting Standards) applicable to large companies are extensive and complex. This regulation adapts disclosure requirements to the administrative and resource capacity of smaller companies.
• Reduction of administrative burden: the explicit objective of the standard is to enable SMEs to respond to their clients' demands without incurring disproportionate costs.

Economic and operational impact

The impact is not a fine or direct cost imposed by law. The impact is commercial and competitive: SMEs that adopt this standard will have an advantage in tenders and contracts with large European groups; those that do not may lose contracts to competitors that do comply.

The concrete operational consequences are:

• Competitive advantage in tenders: large corporations obliged to report their value chain will prefer suppliers that already have structured and verifiable ESG data.
• Maintenance of business relationships: without ESG data, a supplier may be excluded from the approval process of a large client that needs that information for its own report.
• Reduced implementation cost: the standard is designed to be manageable by SMEs, although the regulation does not specify a concrete amount for adaptation costs.
• Cost of not adopting it: potential loss of contracts with large European corporations that need sustainability data from their value chain.

Who does it affect?

• SMEs and medium-sized enterprises that supply goods or services to large European corporations subject to the CSRD.
• Companies that fall below the mandatory CSRD threshold but are part of supply chains of groups that are obliged.
• Suppliers in industrial, manufacturing, logistics, technology or services sectors with large clients in the EU.
• Companies that participate in tenders or competitions with large European corporations where ESG criteria are increasingly relevant.
• CFOs, operations directors and procurement managers who manage relationships with large European clients.

It does not directly affect companies that operate exclusively with clients outside the scope of the CSRD or that are not part of value chains of large European groups.

Practical example

Imagine a Spanish industrial components company with 45 employees and 8 million euros in annual revenue. One of its main clients is a German machinery group with more than 500 employees, obliged to submit a sustainability report under the CSRD.

That German group needs ESG data from its suppliers to complete its own report. Until now, the Spanish company received ad hoc questionnaires from each large client, without a standard format, which generated duplicate work and inconsistent responses.

With the Commission Delegated Regulation (EU) 2026/1560, the Spanish company can voluntarily adopt the simplified standard, prepare a structured ESG disclosure once and share it with all its large clients that request it. The result: less administrative burden, faster response to its clients and greater likelihood of remaining an approved supplier against competitors that do not have that information prepared.

What should companies do now?

1. Identify if your large clients are subject to the CSRD: if any of your main clients exceed the CSRD thresholds (more than 500 employees or large listed companies), they are likely already asking you or will ask you for ESG data.
2. Assess whether you receive sustainability data requests: review the supplier approval questionnaires you receive. If they include questions about environment, working conditions or governance, you are already on your clients' ESG radar.
3. Decide whether to adopt the voluntary standard: if you have several large European clients, adopting the standard of Regulation 2026/1560 can save you time and improve your competitive position. If you only have one large client, assess whether the effort is worth it.
4. Prepare a basic ESG disclosure under this standard: collect data on energy consumption, emissions, working conditions and governance structure. The standard is designed to be manageable without significant resources.
5. Communicate it to your large clients: once the disclosure is prepared, inform your clients that you comply with the voluntary standard of Regulation (EU) 2026/1560. This strengthens your position as a reliable supplier.
6. Consult a specialist advisor in corporate sustainability if you are unclear about what data to collect or how to structure the disclosure under this standard.

Official source

Consult the complete regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601560