EU publishes voluntary sustainability standard for companies with more than 1,000 employees and caps value chain reporting requirements

Delegated Regulation (EU) 2026/1560 of 3 July 2026 supplementing Directive 2013/34/EU of the European Parliament and of the Council by establishing sustainability reporting standards for voluntary use by undertakings protected by the value chain cap was published in the Official Journal of the European Union on September 21, 2026. As we previously mentioned in this publication, this regulation constitutes one of the key components of the sustainability reporting simplification package deriving from Directive (EU) 2026/470 (Omnibus I).

The voluntary standard is aimed at undertakings that, on their balance sheet date, do not exceed an average number of 1,000 employees during the preceding financial year and are not therefore subject to the mandatory sustainability reporting requirements under articles 19a and 29a of Directive 2013/34/EU. These companies will be able to use the voluntary standard to respond to requests for sustainability information from large companies, banks, investors and corporate clients that form part of their value chain. 

The regulation establishes two different modules:

1. Basic module: B1-B11

This is the minimum reporting level and the recommended option for micro-undertakings. It covers nine thematic areas:

• General information (B1–B2): disclosure of the selected reporting option (basic only or basic + comprehensive), statement of compliance, general company data (legal form, NACE code, balance sheet, workforce, country of operations, geolocation of sites) and statement regarding sustainable transition practices, policies and initiatives. 
• Energy and greenhouse gas emissions (B3): total energy consumption (MWh), with a breakdown of renewable/non-renewable energy and gross Scope 1 and Scope 2 emissions in tonnes of CO₂ equivalent. Voluntary for undertakings with 10 employees or less. 
• Pollution (B4): emissions of pollutants to air, water and soil where there is a legal obligation to report them or they are voluntarily reported according to an Environmental Management System. 
• Biodiversity (B5): identification of facilities in or near biodiversity-sensitive areas. 
• Water (B6): total water withdrawn and, where there are processes that significantly consume water, net water consumption and amount of water consumed in areas with water stress. 
• Circular economy and waste (B7): disclosure of whether or not circular economy principles are applied, total waste (hazardous/non-hazardous), proportion of waste recycled and, in sectors with significant material flows, annual mass of materials used. 
• Workforce (B8): number of employees by type of employment contract, gender and country. 
• Health and safety (B9): recordable work-related accidents (number and rate) and, where applicable, fatalities as a result of occupational accidents or diseases. 
• Remuneration, collective bargaining and training (B10): disclosure on compliance with minimum wage, gender pay gap (where mandatory), employees covered by collective bargaining agreements, and average number of training hours. 
• Corruption and bribery (B11): Convictions and fines for corruption and bribery. 

2. Comprehensive module (C1-C9)

This may only be applied if the basic module has been adopted beforehand. It adds nine additional areas aimed at satisfying information requests from banks, investors and large corporate clients:

• Business model and strategy (C1): key products and/or services, significant markets, main business relationships, and key sustainability-related elements of the strategy. 
• Further information on practices and policies (C2): description of the practices reported under disclosure B2, indicating whether they cover suppliers or clients, and the person or body responsible for their implementation. 
• Scope 3 emissions: voluntary quantification of the 15 types of Scope 3 emissions identified by the GHG Protocol, considered particularly relevant in manufacturing, agrifood, real estate construction and packaging processes.  
• Climate transition targets (C3): GHG emission reduction targets in absolute values (Scopes 1, 2 and, if applicable, 3), providing base year, target year and planned actions, as well as information on transition plans in high-climate impact sectors. Voluntary for undertakings with 10 employees or less.
• Climate risks (C4): description of climate-related hazards and transition events, assessment of exposure and sensitivity of assets, time horizons and adaptation actions. 
• Additional workforce information (C5): turnover rate and, voluntarily, gender ratio at management level and among external workers. Voluntary for undertakings with 10 employees or less.
• Human rights policies (C6): existence of a code of conduct or human rights policy (and whether it covers child labor, forced labor, discrimination, etc.) and complaints-handling mechanism. Voluntary for undertakings with 10 employees or less.
• Human rights incidents (C7): confirmed incidents involving the company’s own workforce and workers in the value chain. Voluntary for undertakings with 10 employees or less.
• Revenue from certain activities (C8): revenues from prohibited weapons, tobacco, fossil fuels and the production of specific chemicals. 
• Gender diversity ratio in the governance body (C9): gender diversity ratio on the board or equivalent body. 

The standard also acts as a value chain cap: companies obliged to report sustainability information cannot require companies in their value chain with less than 1,000 employees to provide information that exceeds the essential datapoints set out in Annex II of the regulation. This cap only applies to the gathering of information for sustainability reporting purposes under laws transposing Directive 2013/34/EU, and does not affect requests deriving from other national or Union legislation.

Delegated Regulation (EU) 2026/1560 entered into force on September 24, 2026 (three days after its publication), although article 3 relating to the value chain cap will apply to financial years starting on or after January 1, 2027. 

Delegated Regulation (UE) 2026/1560 has a twofold practical impact. On the one hand, it provides a standard and proportionate framework for companies with 1,000 employees or less to respond to requests for sustainability information from large undertakings, financial institutions and investors, reducing the proliferation of ad hoc questionnaires and the associated administrative burden. Moreover, its voluntary adoption can enhance ESG transparency and improve access to commercial opportunities and sustainable finance.

On the other hand, companies subject to reporting obligations must adapt their data collection processes by January 1, 2027, since they will no longer be able to require entities in their value chain with 1,000 employees or less to provide information that exceeds the essential datapoints set out in Annex II. Accordingly, sustainability-related questionnaires, contracts and due diligence processes should be reviewed to ensure their alignment with the new regulatory framework.