Position and Statement
Positioning on the revised voluntary European Sustainability Reporting Standards (VS) in the context of the Omnibus I simplification package (Feedback on the revised VS)
Federation of German Industries e.V.
Date: 03 06 2026
Summary
The BDI welcomes the opportunity to comment on the draft of the Standard for voluntary sustainability reporting (VS) and regards it as a practical andcomparativelyeasy-to-applystandard. We recognize and appreciate the Commission’s efforts to introduce targeted improvements to EFRAG’s original work with the objective of alleviating reporting burdens on small and medium-sized enterprises (SMEs).
We appreciate that the issue of compatibility with the ESRS disclosure requirements under the CSRD has been addressed and adequately implemented and explicitly support the underlying objective of the value chain cap. Many SMEs are confronted with indirect sustainability reporting requirements as a result of requests from their business partners. The VS has the potential to address these requests, avoid duplication and thus contributes to a harmonized approach to sustainability reporting. An appropriate level of practical applicability, combined with meaningful relief for SMEs, is essential for the widespread use of the VS. In our view, this requirement is largely met by the Draft on the VS. Large parts of our membership consider the standard to be user-friendly and suitable for companies that are not subject to mandatory sustainability reporting requirements.
Furthermore, the BDI emphasizes that companies that fall within the scope of voluntary reporting under the CSRD due to value chain requests constitute a heterogeneous group. Larger SMEs generally face fewer challenges in applying the standard than smaller enterprises, for which even the basic module of the VS represents a significant challenge. This applies in particular to the reporting of additional industry specific data, such as Scope 3 emissions (para. 12). In this light, the BDI welcomes the removal of mandatory disclosures on GHG intensity, and the gender pay gap in the new draft, as well as the significant simplification of detailed biodiversity reporting requirements. Further, the classification of Scope 3 emissions as sector-specific additional information (“consideration”) is explicitly supported. It is crucial, however, that these disclosures do not effectively become an indirect requirement through obligations arising from the value chain.
However, in this early phase of application, several questions remain from the perspective of companies:
▪ First, the distinction between the Basic Module and the Comprehensive Module is not yet fully convincing. In practice, the obligation to provide information in the value chain is determined by Article 3 and by whether information is “necessary”, “voluntary” or “necessary if applicable” - not by the structure of the chapters. From the perspective of the BDI, it would be more practical and clearer if the Basic Module represented the mandatory core for value chain information requests, while the Comprehensive Module remained genuinely voluntary.
Information requests along the value chain should therefore be limited to the Basic Module and should not extend to the Comprehensive Module.
▪ Second, the specification of reporting units can improve comparability. However, practical applications have shown that the same information is measured differently across regions. This is particularly relevant in waste, where it can be difficult to identify appropriate conversion factors. We therefore recommend allowing companies, in justified exceptional cases, to deviatefrom the prescribed units where conversion would be disproportionate or would reduce the reliability of the information.
▪ Finally, since the value chain cap applies only to companies with fewer than 1,000 employees, a regulatory gap arises for companies that exceed this threshold but do not meet the CSRD application criteria of a net turnover of more than €450 million and are therefore not subject to CSRD reporting obligations. This gap should be closed by extending the value chain cap to cover these companies as well.
In the further course of the process, it is crucial that coherence between the VS and the ongoing revisions to the European Sustainability Reporting Standards (ESRS) and the Sustainable Finance Disclosure Regulation (SFDR) is further improved and ensured. During the revision of ESRS and SFDR, information requirements along the value chain should consistently reflect what is realistically achievable for SMEs, to avoid disproportionate burdens. The objective should be to reduce reliance on supplier-based information as far as possible
Overall, the VS should therefore not be expanded beyond the existing draft and must be recognized by CSRD reporting large enterprises, investors, financial institutions, and banks as an adequate and sufficient fulfilment of value-chain information requirements, to ensure broad acceptance. At a time when European businesses are facing increasing competitive pressures and economic uncertainty, it is essential that corporate resources can be directed towards innovation and investment rather than disproportionate compliance requirements. The aim is to significantly limit the “trickle down” effect and substantially reduce the administrative burden on SMEs. This is crucial to safeguarding the improvements achieved through the Omnibus procedure and to sustainably strengthening the competitiveness of SMEs in Germany.
We would appreciate it if these considerations were taken into account in the further consultation on the draft To provide legal certainty for businesses, it is essential that implementation be carried out as swiftly as possible in line with the Commission’s timeline. Only under these conditions can companies operate with confidence in a stable and predictable legal framework.
Federation of German Industries
German Lobbyregister Number R000534
Address Breite Straße 29 10178 Berlin
Postal Address 11053 Berlin
Germany
Contact M: +49 151 51840811
Internet www.bdi.eu
E-Mail j.winkler@bdi.eu