Since March 2026, a client in construction may no longer demand more sustainability information from a contractor or installer with one thousand employees or fewer than what is set out in the voluntary EU standard for unlisted SMEs, the VSME. In concrete terms, this means: detailed specifications per building material, per truck journey, or per subcontractor typically fall outside that scope. What does fit within that standard, a client may continue to request.
This rule is called the supply chain obligation and is found in the directive on sustainability reporting. The idea behind it is that large, reporting-obligated enterprises must not simply pass on their own compliance obligations to smaller suppliers in their value chain. For construction this is relevant because clients — project developers, housing associations, large contractors who engage subcontractors — often want to drill down precisely on material use and transport, because these are the line items that most heavily determine their own CO2 figures.
Material use: what may and may not be requested
The VSME standard calls for an overview at a high level: energy consumption, the main emission streams, and a general picture of where the greatest impact lies in operations. What the standard does not call for is a material-by-material lifecycle assessment of every steel beam or every cubic metre of concrete that is processed. A client who requires a complete LCA per material stream for each project is in practice often asking for more than what a supplier of this size is obligated to provide.
The same applies to certificates of origin traced down to supplier level of the supplier's supplier. That kind of chain depth is part of the reporting obligations of large enterprises themselves, not something they may impose as a requirement on a smaller party in the value chain. A contractor may ask its own suppliers about this if it is useful for operations, but the client may not impose it as an obligation on a smaller party in the chain.
Transport to the construction site
Transport boundaries are similarly drawn. A rough estimate of fuel consumption of its own fleet, based on fuel receipts or mileage records, fits the VSME level. A detailed statement per journey, per driver, per load factor, or per route — sometimes requested to feed a client's own scope 3 reporting — goes further than what may be demanded of a supplier with this workforce.
This distinction is precisely why the question "what does this mean for my business" cannot be answered in general terms: it depends on the exact wording of the question, not on the sector as a whole. A question such as "what is your estimated fuel consumption for construction site transport" is different from "provide per journey the CO2 emissions, substantiated with external verification". The second example adds requirements — verification, level of detail — that the VSME does not impose.
How you assess this in practice
Because the boundary differs per question, it helps to test each question individually against what the VSME actually requires, rather than assessing the entire questionnaire at once. Some questions in a list fit well within the standard, others go just beyond it — and these can be scattered throughout a single client document. in a few questions see whether this affects your situation provides a first indication of this without you having to work through the entire standard.
If a question goes beyond what the standard allows, that is not inherently a problem between you and the client — it is primarily something to address clearly. You can indicate that the requested information falls outside the voluntary standard that applies to companies of your size, and offer what does fall within that standard. This is generally a more constructive conversation than simply leaving the question unanswered. An overview of how such an explanation might look, and of the underlying sources, can be found at the topics that have been worked through per situation.
What this is not
This explanation is not legal advice and not an assessment of a specific questionnaire. The scope of reporting obligations is set out in the corporate sustainability reporting directive and the precise interpretation of it can differ depending on the situation; if you have doubts about a specific case, you can consult a lawyer or the competent supervisory authority. How esgia.eu uses the VSME, the directive and the emission factors as sources is described at how the assessment is made, and frequently asked questions about what does and does not fall under the standard are collected at the answers to the most frequently asked questions.
If you have a questionnaire from a client that you cannot immediately place, paste the questions for free into the scope check. You will immediately see which questions fit within the VSME standard and which may fall outside it — without needing an account.