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ESG: large customers can only ask SMEs for information on a closed list
A new EU regulation sets the voluntary sustainability reporting standard and, from 2027, limits the ESG data that companies subject to mandatory reporting can require from suppliers with up to 1,000 employees.
New legislation
Up to 1,000 employees
Applies to financial years from 1 Jan 2027
On 21 September 2026 the European Union published Delegated Regulation (EU) 2026/1560, which turns the voluntary sustainability reporting standard for companies that are not required to report into binding law. For most Portuguese SMEs the practical effect is a different one: it caps the ESG information that large customers can ask them for.
What changes
- A voluntary standard backed by a regulation. Companies not required to report on sustainability may report under the standard in Annex I, which has a basic module and a comprehensive module, and may use EFRAG’s practical guidance (Article 2).
- A value-chain cap. Companies subject to mandatory reporting may only require the data points listed in Annex II from companies in their value chain with an average of up to 1,000 employees (Articles 1 and 3).
- Even fewer requests for micro-companies. Annex II separates companies with 10 or fewer employees from the rest.
- No mandatory external assurance. The recitals state that companies applying this standard do not have to obtain assurance on the information they report.
- Recommendation (EU) 2025/1710, the previous version of this standard, ceases to have legal effect.
How much can be requested
- Company with up to 10 employees: 9data points
- Company with 11 to 1,000 employees: 23data points
| Topic | Up to 10 employees |
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Source: Jornal Oficial da União Europeia — Regulamento Delegado (UE) 2026/1560