Compare Your Footprint — Carbon Intelligence Platform

If you supply products or services to customers in the European Union, a regulatory change that came into force on 18 March 2026 will shape what carbon and sustainability data those customers can ask you for. The change is called the Voluntary SME Standard — VSME for short — and it arrives as part of the EU Omnibus I Directive.

The good news: the Omnibus actually reduced the number of companies required to report under the EU’s Corporate Sustainability Reporting Directive (CSRD) by roughly 85%. The flip side is that it introduced a new framework that standardises exactly what data large EU companies can request from smaller suppliers like you.

Here is what that means in practice, and the five actions you should take now.

What the Omnibus Directive changed

Before March 2026, the CSRD was set to bring around 50,000 European companies into mandatory sustainability reporting. The Omnibus Directive slashed that to companies with more than 1,000 employees and over €450 million in net turnover. If your EU customer was a mid-sized company dreading CSRD compliance, they may now be exempt.

But the Directive introduced something else: the concept of a “protected undertaking.” Companies below the 1,000-employee threshold can now legally refuse data requests from their supply chain partners that go beyond what the VSME standard requires. In other words, the VSME is becoming the ceiling — and the floor — for supply chain data requests directed at SMEs.

What the VSME standard will actually require

The European Commission is expected to publish the VSME delegated act in June 2026. While the final text is not yet available, the drafts and consultation documents point to a streamlined set of data points designed to be proportionate for smaller businesses. Based on what we know so far, expect the standard to cover:

Basic environmental metrics

Total greenhouse gas emissions, likely split between Scope 1 (direct) and Scope 2 (purchased energy), with a simplified approach to material Scope 3 categories. The emphasis is on activity-based data rather than complex modelling.

Energy consumption

Total energy use, split by renewable and non-renewable sources. This aligns closely with what UK SMEs already report under SECR if they meet the qualifying thresholds.

Social and governance basics

High-level workforce composition, health and safety indicators, and basic governance disclosures. These are intentionally lighter than full CSRD requirements.

A narrative sustainability statement

A short description of the company’s principal sustainability risks, opportunities, and any targets or transition plans in place.

The critical point is proportionality. The VSME is not the CSRD. It does not require the detailed, audited disclosures that large companies must produce. It is designed to give EU supply chains a common data format without crushing smaller suppliers under reporting burdens.

Why this matters for UK SMEs specifically

Post-Brexit, UK businesses are not directly subject to EU regulation. But if your revenue depends on EU customers, their regulatory obligations become your commercial reality. When a German manufacturer or French retailer needs supply chain emissions data for their own CSRD or VSME-aligned reporting, they will ask their suppliers — including you.

The VSME standard gives both sides clarity. Your EU customer knows what they can ask for, and you know the maximum they can reasonably demand. That is a significant improvement over the current situation, where data requests vary wildly between customers and often demand information that is disproportionately burdensome for an SME to produce.

Five actions to take before June 2026

1. Audit your EU customer exposure

List every customer headquartered in the EU or subject to CSRD reporting. These are the relationships where VSME-aligned data requests are most likely to arrive. If more than 20% of your revenue comes from EU customers, this should be high on your priority list.

2. Start measuring your carbon footprint now

The VSME will almost certainly require Scope 1 and Scope 2 emissions as a minimum. If you are not already measuring these, begin now using activity-based data — actual energy bills, fuel records, and transport logs rather than spend-based estimates. Activity-based data will satisfy VSME requirements and give you more accurate, defensible numbers.

3. Get your energy data in order

Total energy consumption split by source type is a near-certainty in the VSME. Pull together your electricity, gas, and fuel invoices for the last 12 months. If you have renewable energy contracts or on-site generation, document these clearly.

4. Prepare a short sustainability narrative

Even before the delegated act publishes, you can draft a simple statement covering what your business does to manage its environmental impact, any reduction targets you have set, and the main sustainability risks relevant to your sector. This does not need to be a 50-page report — two to three pages of honest, factual content will serve you well.

5. Choose the right measurement tool

Spend-based carbon estimates — the kind generated by tools that categorise your bank transactions — will not produce the activity-level data the VSME is expected to require. Invest in a tool that collects actual activity data and produces output aligned with GHG Protocol methodology. When the VSME delegated act publishes, you want to be confident that the data you already have meets the standard.

How CYF helps you get VSME-ready

Compare Your Footprint’s activity-based approach to carbon measurement is designed to produce exactly the kind of data the VSME standard is expected to require. Rather than estimating emissions from your spending patterns, CYF collects actual energy, travel, waste, and supply chain data — then maps it to GHG Protocol categories.

When the VSME delegated act publishes in June 2026, CYF will map its reporting output directly to the required data fields. That means you can respond to EU customer data requests with a single, standards-aligned report rather than scrambling to assemble ad hoc spreadsheets.

The UK businesses that prepare now — before the delegated act drops — will be the ones that respond to their first VSME-aligned data request in hours rather than weeks. And in a competitive supply chain, speed of response signals professionalism.

The bottom line

The VSME standard is not a threat — it is clarity. For the first time, UK SMEs supplying into the EU will have a defined framework for what data they need to provide and, just as importantly, what they can legitimately push back on.

The window to prepare is narrow. The delegated act is expected in June 2026, and the businesses that already have their emissions data, energy records, and sustainability narrative in order will have a significant commercial advantage.

Start measuring now. Get your data into a format that will withstand scrutiny. And when that first VSME-aligned request lands in your inbox, you will be ready.

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Sources: EU Council Omnibus I Directive approval, Sedex Omnibus explainer, BDO CSRD scope analysis