There Is a Ceiling on What a Buyer Can Ask: The Line the EU Omnibus Drew

Key summary

The EU Omnibus revision put a cap on the ESG information a client company can demand from its suppliers. Suppliers with 1,000 or fewer employees cannot be required to provide information beyond the voluntary SME standard, and contract clauses that force this are unenforceable. This piece lays out the underlying provisions article by article.

Signals from abroad · July 16, 2026 · 3 min read

Contents (5)

Opening the ESG questionnaire your customer sent you is a daunting experience. There are dozens of line items, your company has nobody assigned to this, and because you wonder whether leaving it blank will hurt the business relationship, you end up filling it in anyway. But on 3 July of this year, the EU drew a ceiling under those demands.

The conclusion first

There is now a limit set in law on the information a supplier has to provide to its customer. Companies with 1,000 or fewer employees cannot be asked for information beyond that scope, and contract clauses that try to compel it are not binding.

What happened

On 26 February 2026, the EU published the so-called Omnibus Directive (Directive (EU) 2026/470) in its Official Journal. The amendment substantially narrowed the scope of corporate sustainability reporting (CSRD) and supply chain due diligence (CSDDD).

Then on 3 July 2026, the Commission adopted the follow-up delegated regulation, finalising the revised reporting standards together with a Voluntary Standard for small and medium-sized enterprises. For suppliers, it is this voluntary standard that matters in practice.

The scope itself has narrowed

Regime	Threshold after the amendment
CSRD (sustainability reporting)	More than 1,000 employees + net turnover above EUR 450 million
CSDDD (supply chain due diligence)	5,000 employees + worldwide net turnover of EUR 1.5 billion
Non-EU (third-country) companies	Net turnover in the EU of EUR 450 million

The figures were checked against the original articles on EUR-Lex. A good many of the Korean-language explainers published in 2024-2025 use the pre-amendment thresholds, so reading them today will give you the wrong answer about whether you are in scope.

Five provisions that apply directly to suppliers

Basis	What it says
Amended 2013/34/EU §19a(3)	A company with 1,000 or fewer employees cannot be required to provide information beyond the scope of the voluntary standard. If more is requested, the requester must say which items go beyond it, and contract clauses that try to compel it are not binding
CSDDD §8(2a)(a)	Information requests are limited to what is necessary, and for partners with fewer than 5,000 employees they are allowed only where the information cannot reasonably be obtained by other means
CSDDD §10(2)(e)	The customer must provide capacity-building and training support to small and medium-sized suppliers, and where the cost of compliance threatens their viability, financial support as well
CSDDD §10(5)	Contract terms imposed on suppliers must be fair, reasonable and non-discriminatory
CSDDD §10(5)	Where compliance verification is carried out on a supplier, the cost of third-party verification is borne by the customer

The last item is the one people feel most in day-to-day work. It is common practice for the supplier to absorb verification costs, but the directive puts them on the customer.

What not to misread

The regulation has not gone away

The narrowing of scope concerns who is directly subject to EU law. What your customer asks of you because of its own targets (RE100, carbon neutrality) has not changed. What has changed is that there is now a standard against which to weigh the basis and the limits of a request.

One more thing. These provisions regulate companies that are subject to EU law. You cannot conclude that they apply as-is to a Korean customer making demands of a Korean supplier. That said, since a good many customers sell into the EU market and have cited EU regulation as the basis for their requests, this does give you a starting point for asking "on what basis are you requesting this?"

What you can do now

When you receive a customer questionnaire

Establish the basis for the request — is it the customer's own policy, or implementation of EU regulation?
Check your own employee count against the threshold (are you at 1,000 or fewer?)
Check whether the requested items fall within the scope of the voluntary standard (VSME)
If third-party verification is requested, confirm in writing who bears the cost
Re-read your contract to see whether it contains an information-provision obligation

Simply checking gives you room to negotiate. Requests that are broad without a basis for it are not rare.

[Source: Directive (EU) 2026/470 (Omnibus Directive), 2026-02-26]
[Source: CSDDD consolidated text (as amended by the Omnibus), 2026-03-18]
[Source: European Commission — adoption of the revised sustainability reporting standards, 2026-07-03]

Note: Article numbers and figures follow the original texts on EUR-Lex. This is not legal advice on any individual contract or business relationship, and we recommend that your actual response be worked out alongside your contract and a professional review.

OpenEnergy Editorial Team

Signals from abroad

We pick out the Korean and global energy news that actually matters, and report it briefly and accurately.

Talk to an expert about your company's K-RE100 transition

Tell us about your situation and someone here will write back with the right transition route.

CompanyYour name

EmailPhone

How can we help?I agree to receive information about renewable energy from OpenEnergy. (optional)

We use these details only to answer this enquiry.

"We Make Semiconductors, So CBAM Isn't Our Problem" — Check Your Export Declaration First

08/21/26

EU CBAM Goes Live: What It Means for the Semiconductor Supply Chain

07/02/26

RE100 Criteria Changed Again: Three Things Korean Suppliers Should Check Now

07/01/26

Related resources

All resources →

Stop hunting for REC, PPA and tariff prices

We send REC, SMP, carbon allowance and green premium prices, plus the Korean energy policy changes companies need to track.