Briefing: What Businesses and Investors Need to Know About the Omnibus 1 Value Chain Cap on Information Requests', 20 May 2026

A new legal briefing by Frank Bold unpacks the new restrictions on information requests to business suppliers following the Omnibus 1 revisions to the CSRD and CSDDD, and explains the practical implications for companies.

As part of the sustainability reporting and due diligence requirements under the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), companies need to request sustainability-related information from their value chain partners.

The Omnibus 1 Directive introduced restrictions on how and when such information requests can be made in order to protect suppliers from disproportionate requests. These consist of the value chain cap under the CSRD and the limits on information requests under the CSDDD. For companies in scope of these directives, it is important to understand the new restrictions.

Our legal briefing breaks down:

The scope and limitations of both caps, specifying what type of information requirements are legitimate

The conditions on information requests, including the statutory right to refuse and how in-scope companies should interact with protected undertakings

The interplay between these two legislations

The practical implications for companies, as well as how companies can avoid unnecessary duplication

The publication also points to legal uncertainties resulting from the European Commission’s proposed Voluntary Standard when it comes to due diligence scoping, GHG data and climate risk information and proposes practical steps for companies to preserve effective supply chain management while remaining fully compliant with the caps...