The EACB welcomes the new Sustainability Reporting Standard for Voluntary Use (VS) as a significant step toward a more proportionate ESG data framework for undertakings outside the mandatory CSRD scope, viewing it as a tool to reduce fragmented information requests and standardise the sustainability dialogue between SMEs and banks. Compared with the VSME recommendation, the VS offers better structure and lower complexity. However, the EACB stresses that the framework, including the value chain cap, must be fully operational from its date of entry into force to avoid a regulatory vacuum. It also questions the 10-employee proportionality threshold as too low and inconsistent with the 1,000-employee threshold used elsewhere, suggesting an upward revision.
The EACB warns that the layered datapoint architecture (multiple categories, qualifiers like "if applicable", "necessary", "necessary if" and "voluntary", and mixed "shall"/"should" wording) is disproportionately complex for a voluntary framework aimed at SMEs. Conditional categories such as "necessary if applicable" need clearer criteria to ensure consistent interpretation. The EACB also flags that the new categorisation has narrowed the datapoints covered by the value chain cap. In this regard, we ask for arrangements that still facilitate decision-useful Scope 3 information for banks' financed-emissions reporting, alongside restored granularity on biodiversity.
Finally, the EACB welcomes the clarification that the value chain cap applies only within the CSRD context and not to data requests for prudential, supervisory, risk management or financing purposes. it is regrettable that this key guidance is included only in the recitals rather than being anchored in the enacting terms, where it would provide stronger legal certainty and send a clearer signal to all stakeholders.
It should also be acknowledged that the VS is intended as a proportionate transparency framework rather than a comprehensive prudential ESG risk management standard. Consequently, while the VS may serve as an important baseline for sustainability-related information, financial institutions may still require additional company-, sector- or asset-specific data to meet their own sustainability reporting requirements, supervisory expectations, portfolio steering, climate and nature-related assessments, or individual financing decisions.