What may a client no longer ask a transport and logistics company?
Since March 2026, there is a limit on what a reporting-obligated client may request from a supplier with one thousand employees or fewer: no more than what is permitted in the voluntary EU standard for non-listed SMEs (VSME). For a transport company, this concretely means that questions about total fuel consumption, the number of vehicles and the average CO2 emissions of the fleet are generally permitted, while detailed trip records per vehicle, real-time telematics data or a complete emissions inventory of subcontractors quickly go beyond what the standard requires.
The reason this often goes wrong in transport and logistics is that clients try to close their own scope 3 figures and believe they need detailed data from their transport providers for this. That need is understandable, but the supply chain obligation exists precisely to prevent that need from being shifted to smaller companies that are not themselves subject to reporting obligations.
Fuel: what is permitted and what is not
The VSME standard asks for the total consumption of fuels, broken down by type (diesel, petrol, LNG, electricity for charging stations) and the total emissions resulting from it. A client may therefore ask for this, and most transport companies can obtain this figure directly from fuel receipts or fuel card administration.
What the standard does not ask for is a breakdown per trip, per customer or per route. This type of detail belongs to a company's own operational management, not to a sustainability questionnaire from a client. If asked for this, it is a question that under the supply chain obligation may be declined — with wording that explains that the requested level of detail falls outside the VSME standard, not that you are unwilling to cooperate.
Fleet: composition versus performance per vehicle
Questions about fleet composition — number of vehicles, fuel type, average age — generally fit within what the standard asks for. Questions about the Euro standard of each individual vehicle, about maintenance data or about CO2 emissions per kilometre per vehicle go beyond what an SME transport company needs to provide.
The distinction is not always clear-cut, and that is precisely why the VSME standard itself remains the starting point. In case of doubt, it is wiser to test the question against the standard than to determine on intuition what seems reasonable. in a few questions to see whether a question falls within the limit provides a first indication there, without you having to study the standard yourself.
Outsourced transport and subcontractors
For transport and logistics, this is often the most difficult point. A client wants to know what the total chain causes in emissions, and therefore sometimes asks for emissions figures from subcontractors that a transport company uses. For a company with one thousand employees or fewer, providing detailed third-party data generally goes beyond what the VSME standard requires; that standard asks for the company's own operations, not a full supply chain audit of subcontractors.
This does not mean the question may never be asked — the standard allows room for a qualitative explanation of the main supply chain risks, without requiring hard figures per subcontractor. The difference between a description and a complete data inventory is precisely where the supply chain obligation makes the distinction.
Why this distinction is not always immediately clear
The supply chain requirement is new, and many procurement departments are still working with questionnaires drawn up before March 2026. This is usually not bad faith, but a matter of updating. A clear formulation that refers to the VSME standard and to the threshold that applies to your company size works better in practice than a blanket refusal.
Which questions exactly fall within the standard and which fall outside it varies by topic — from fuel to personnel figures to waste streams. A complete overview per situation, also specific to transport and logistics, can be found per topicHow the assessment itself is conducted and which sources are used in the process can be read on the page on how the assessment works.
This guidance is descriptive and intended to help you recognize the supply chain requirement in a concrete questionnaire; it is not legal advice on your specific situation. If you are in doubt about an individual question or about the scope of the standard for your business, a lawyer or the competent supervisory authority is the appropriate contact.
Do you want to quickly find out which questions from your client's list fall within the VSME standard and which do not? Paste the questionnaire into the free capcheck or first read the answers to the most frequently asked questions about the supply chain requirement.