Compare Your Footprint — Carbon Intelligence Platform

If you run a UK manufacturing business or supply services to European customers, you’ve likely received a carbon questionnaire. It’s dense. It looks official. It feels urgent. Your instinct is probably to fill it all in—because what if refusing costs you the customer?

Stop. You need to know that EU regulations now cap what data large companies can demand from SME suppliers. And many of those questionnaires exceed what you’re actually required to provide.

What changed: the Omnibus Directive and the VSME standard

In February 2026, the EU adopted the Omnibus I simplification package, amending the Corporate Sustainability Reporting Directive (CSRD). The headline: 80% of companies previously in scope are now exempted.

But here’s the part that affects you directly. The CSRD requires large companies to report Scope 3 emissions—the emissions in their supply chain. To do that, they send questionnaires to suppliers. The problem is obvious: if they can ask whatever they want, the compliance burden cascades downstream onto SMEs.

The Omnibus Directive introduced a safeguard: small and medium-sized enterprises (SMEs) with fewer than 1,000 employees can refuse data requests that exceed the VSME standard.

VSME stands for the Voluntary Sustainability Reporting Standard for SMEs. The EU published it in December 2024 as a lightweight reporting framework for companies too small to fall under CSRD reporting obligations. It’s designed to be achievable without specialist sustainability infrastructure.

VSME has two modules:

Basic Module: Total greenhouse gas emissions (Scope 1 and 2, plus basic Scope 3 from purchased goods and services). Energy consumption. Number of employees and revenue.

Comprehensive Module: The Basic Module plus more granular Scope 3 breakdowns (capital goods, fuel and energy-related activities, waste, business travel, employee commuting). More detailed environmental data (water, waste, air pollutants).

Your EU customer can ask for either one. They cannot ask for more.

What your EU customer can actually ask for

Under VSME Basic Module, a legitimate carbon data request should cover:

Scope 1 and Scope 2 emissions: Direct emissions from operations (gas boilers, company cars) and purchased energy (electricity, steam, heating).
Basic Scope 3 emissions: Specifically, Category 1 (purchased goods and services) and Category 9 (downstream transportation and distribution). These are the biggest emissions sources for most suppliers.
Energy consumption: Total energy use in kWh or equivalent, with a breakdown by source (grid electricity, gas, renewables).
Workforce headcount: Total employees. This contextualises emissions intensity.
Financial data: Annual revenue or equivalent turnover. Again, for intensity benchmarking.

What they cannot demand under VSME:

Product-level lifecycle assessments (LCAs). VSME is organisational, not product-specific.
Full ESRS (European Sustainability Reporting Standards) compliance. That’s for large companies, not SMEs.
Detailed supply chain mapping of supplier emissions.
Third-party assurance or verification (unless your contract explicitly requires it).
Emissions data beyond Scope 1, 2, and basic Scope 3.

Compare Your Footprint (CYF) collects and contextualises exactly the data VSME requires. The CYF platform captures energy, emissions, and workforce metrics, and benchmarks them against your peer group—so you understand whether your performance is typical or needs attention. That’s what satisfies VSME requirements.

How to respond to a carbon data questionnaire

When a carbon questionnaire arrives, follow these steps:

Step 1: Assess the request. Read it line by line. Flag any data points that ask for product-level information, detailed supply chain mapping, or full ESRS compliance. These exceed VSME.

Step 2: Check your size. Are you an SME with fewer than 1,000 employees? If yes, you have legal cover to refuse requests beyond VSME. If you have more than 1,000 employees or more than EUR 50 million revenue, CSRD may apply to you directly—seek accountancy advice.

Step 3: Provide what’s reasonable. Compile VSME Basic Module data: total Scope 1 and 2 emissions, energy consumption, headcount, revenue. If you’ve used CYF, you have this ready. Add a brief methodology note explaining your calculation approach.

Step 4: Push back on excess. For anything beyond VSME, use this language:

“We report under the VSME standard for SMEs as defined in the EU Omnibus I Directive (adopted February 2026). VSME Basic Module data is attached. Additional data points you’ve requested [list them] exceed the VSME scope. Under Article [X] of the Omnibus amendment, we’re not obligated to provide these. If you’d like to discuss how the data we’ve provided contextualises our supply chain footprint, we’re happy to do so.”

This isn’t hostile. It’s legal clarity. Your customer’s procurement team knows this standard exists. They may push back, but you now have grounds to negotiate rather than simply comply.

Step 5: Document the exchange. Keep records of what was asked, what you provided, and any pushback. If your customer is ultimately subject to CSRD audit, a documented good-faith effort to provide VSME data protects both parties.

How CYF helps

Compare Your Footprint is built for UK SMEs navigating exactly this scenario. CYF measures and reports the emissions data VSME requires—Scope 1, 2, and basic Scope 3—in a format that’s ready to share with customers. The benchmark dataset contextualises your emissions against comparable businesses, so you can explain performance with confidence. You’re not guessing or padding figures; you’re reporting actual, benchmarked data that satisfies regulatory expectations.

The bottom line

You don’t need to fill in every blank on a carbon questionnaire. EU law now protects you. Provide VSME Basic Module data. Push back on requests beyond it. Document your response. And if you’re uncertain whether a request is legitimate, check the Omnibus I amendment or consult a sustainability adviser.

The regulations changed to reduce SME compliance burden, not eliminate your customer relationships. Responding with clarity and evidence—backed by the right standard—does both.

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For guidance on measuring VSME-compliant emissions data, explore Compare Your Footprint’s measurement framework.