Being outside the CSRD does not make sustainability information disappear from business relationships. Large customers may still collect supply-chain data; distinguish direct reporting duties from contractual or commercial requests.
What the Omnibus I Directive changes
Directive (EU) 2026/470, in force since 18 March 2026, narrows the CSRD scope. The new EU threshold covers companies exceeding both 1,000 average employees and €450 million in annual net turnover; exceeding only one threshold is not enough.
Member States must transpose the directive by 19 March 2027. Italian businesses must therefore check national transposition and the reporting year concerned before treating an existing obligation as removed or postponed. Groups should also verify the reporting perimeter and consolidated figures.
Can an SME still receive ESG questionnaires?
Yes. An unlisted SME outside the CSRD may still receive requests from customers, banks or partners for supply-chain risk reviews, due diligence, supplier selection, emissions or working-condition data.
The EU changes limit what CSRD-reporting companies may request from SMEs in their value chains, with reference to the voluntary SME standard. This is not a general right to reject every ESG question: consider who is asking, the contract, the purpose and the information actually needed.
What the VSME is for
The VSME is the European voluntary sustainability reporting standard for small and medium-sized businesses, recommended by the Commission in 2025. It provides a proportionate way to organise environmental, social and governance information for value-chain requests.
It has a basic module and a more comprehensive module for additional information. Using it does not make CSRD reporting mandatory; it gives an SME a reusable set of indicators and a basis for explaining missing data or asking customers to narrow requests.
- Separate direct legal duties from commercial requests.
- Ask for purpose, scope, period and format.
- Use VSME as a common reference without claiming CSRD compliance when it does not apply.
A practical approach for supply-chain SMEs
Start with existing data on energy, emissions, health and safety, employees, governance and certifications. For each indicator, record its source, owner, unit, scope and reporting period so it can be reused consistently.
CSRD scope and Italian rules are evolving. Before answering a complex questionnaire or refusing it, verify your status, review the contract and agree a proportionate data set with the customer. Keep submitted versions and distinguish measured values from estimates.
How to handle an ESG request step by step
Identify who sent the questionnaire and why: a customer’s reporting duty, supplier review, bank request and contractual requirement can have different purposes. Clarify the entity and sites covered, reporting year, format and deadline.
Compare questions with VSME and data already held. Record value, unit, period, source and owner; label estimates clearly. If a request goes beyond proportionate information, explain what you can provide, what needs more work and propose a realistic alternative or date.
- Distinguish law, commercial requests and contract requirements.
- Keep definitions, units and reporting years consistent.
- Archive the questionnaire, response and supporting evidence.
Example: a customer questionnaire
A customer requests energy, emissions, injuries and certification data within two weeks. First clarify whether the request covers all sites or only the sites supplying that customer, and whether it asks for the last completed year or the current year.
Send measured values with source and period, label estimates and explain unavailable data. For additional indicators, ask the purpose and offer VSME as a shared baseline. The result is traceable information rather than disconnected figures.