EU Omnibus I Directive (Directive (EU) 2026/470) A2-4: Value chain cap: protected undertakings, self-declarations and requests beyond the voluntary standards (amended Article 19a(3) of Directive 2013/34/EU)

What does A2-4 require?

A reporting undertaking may rely on a value chain undertaking's self-declaration that it has no more than 1 000 employees on average and need not verify it, unless it knows or should reasonably know the declaration is plainly wrong. Such protected undertakings may refuse requests for sustainability reporting data that go beyond the voluntary standards under Article 29ca. The reporting undertaking must not require more than the voluntary standards in contracts or other arrangements made to meet its reporting duties (any such clause is not binding, the rest of the contract stands), and whenever it asks for more it must tell the protected undertaking which items exceed the voluntary standards and that it has a statutory right to decline. Reporting value chain information without exceeding the voluntary standards for protected undertakings counts as compliance. Requests made for other purposes, such as due diligence duties, are unaffected, and no value chain undertaking is obliged to provide data.