The value chain cap, the self-declaration route, the right to decline and the omission conditions apply to consolidated reporting in the same way as to individual reporting.
The requirement, in our words
The value chain protections and omission conditions applied to individual reporting also bind parent undertakings for consolidated reporting: reliance on self-declarations of value chain undertakings with up to 1 000 employees, no contractual demand beyond the voluntary standards, notice of the right to decline for any extra request, deemed compliance when staying within the voluntary standards, a three-year explanation of value chain gaps followed by direct data or estimates, and the four grounds for omitting commercially prejudicial, trade secret, classified or protected information, each disclosed as used and reassessed at every reporting date.
Why it matters
A group cannot avoid the cap by routing requests through subsidiaries. The consolidated provision repeats the protected undertaking definition, the self-declaration, the contract rule and the deemed compliance, and it adds the same three-year transition and omission structure. In practice the group needs one supplier request standard that every subsidiary uses, or the cap will be breached in one country and not another.
What changed
The old Article 29a(3) mirrored the individual value chain duty without the cap. The replacement copies the new individual structure into the consolidated provision.
What to do
- Adopt one group-wide supplier request standard with the voluntary-standards marking and the right to decline.
- Keep a consolidated omission register with the ground, the approval and the reassessment date.
- Check that each subsidiary uses the group standard and record any local deviation.
Evidence to have ready
| Category | Artefact |
|---|---|
| Group reporting | Group-wide supplier data request standard applied by all subsidiaries with the voluntary-standards marking |
| Group reporting | Consolidated omission register with ground, approval and reassessment date for each item |
| Group reporting | Group sustainability statement section on value chain gaps and the improvement plan |
Common failures
- Subsidiaries running their own supplier questionnaires outside the group cap
- Group omission approved centrally but not disclosed in the consolidated report
Dates
Applies to consolidated financial years starting on or after 1 January 2027. The voluntary standards were due by 19 July 2026.
The question to test
Do all subsidiaries use the same request standard, and can you show the cap was applied in each one?
Cross-references
A2-4 Value chain cap · A2-6 Omission conditions · A2-8 Consolidated statement threshold
Source
Article 2(5)(b)(i) and (iii), amending Article 29a(3) of Directive 2013/34/EU; OJ L 2026/470, 26 February 2026; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026L0470. Our statement of the duty, read from the Official Journal text and the held control record, not the instrument verbatim.
Not legal advice; does not certify. A reading of the duty and the evidence commonly sampled, not a substitute for the Official Journal text, the national transposing measure or your auditor's judgement.