Requirement · RPT-03

Do not seek from value-chain undertakings with 1000 or fewer employees any sustainability information beyond the voluntary reporting standard, except sustainability information commonly shared sector-wide

Addressee Large undertakings preparing individual or consolidated sustainability statementsAct COM(2025) 81, 2025/0045 (COD)Article Art. 2(2) and 2(4), amending Art. 19a(3) and Art. 29a(3) of Directive 2013/34/EUClass Businesses

What changes

Large reporting undertakings gain a new restriction on what they may demand from value-chain counterparties with 1000 or fewer employees; those smaller counterparties correspondingly gain protection from open-ended information requests.

Prior rule vs new rule

Prior rule

Obligation

Article 19a(3) of Directive 2013/34/EU requires undertakings to report information about the undertaking’s own operations and about its value chain.

New rule

Trigger

Value-chain counterparty does not exceed 1000 employees on average during the financial year

Obligation

Do not seek from value-chain undertakings with 1000 or fewer employees any sustainability information beyond the voluntary reporting standard, except sustainability information commonly shared sector-wide

Who is affected

Addressee

Large undertakings preparing individual or consolidated sustainability statements

Class

Businesses

Sectors

No sector named — applies by size or activity

Applies

Once transposed by Member States (transposition due within 12 months of this Directive's entry into force)

Burden drivers

No burden drivers recorded on this provision.

If you are under 1000 employees, this protects you as a value-chain counterparty rather than binding you directly.

Source text

Verbatim

Member States shall ensure that, for the reporting of sustainability information as required by this Directive, undertakings do not seek to obtain from undertakings in their value chain which, on their balance sheet dates, do not exceed the average number of 1000 employees during the financial year any information that exceeds the information specified in the standards for voluntary use referred to in Article 29ca, except for additional sustainability information that is commonly shared between undertakings in the sector concerned.

View source →

Settled later in secondary legislation. The cap's ceiling is set by the voluntary reporting standard the Commission is due to adopt by delegated act under the new Art. 29ca.