For the first three years of reporting, an undertaking with incomplete value chain information must explain the efforts made, why the information was not available and how it will obtain it; after that it must use directly obtained information or estimates.
The requirement, in our words
During its first three years under the sustainability reporting duty, where value chain information is incomplete, an undertaking must explain what it did to obtain it, why some of it could not be obtained and how it plans to obtain it. After those three years it must meet the value chain requirements using data obtained directly from value chain undertakings or estimates, as appropriate. The transition now runs from the undertaking's own first reporting year rather than from the Directive's application date, and the second subparagraph of Article 19a(3) is deleted.
Why it matters
The provision gives a new reporter a runway without allowing a permanent gap. The explanation is not a free pass: it has to name the efforts and the plan, which gives the auditor and the board something to test. The end of the runway changes the method, not just the wording, because estimates become the fallback only after the three years.
What changed
The old text allowed estimates where information was unavailable. The replacement separates the first three years, with an explanation duty, from the period after, with a direct-information-or-estimates duty.
What to do
- Record the first reporting year and calculate the end of the three-year period.
- Write the value chain paragraph with the efforts, the reasons and the dated plan.
- At the end of the period, switch to direct information or estimates and document the method for each estimate.
Evidence to have ready
| Category | Artefact |
|---|---|
| Value chain data collection | Sustainability statement paragraph on value chain data gaps, efforts made and the improvement plan |
| Value chain data collection | Register recording the first reporting year and the end of the three-year transition |
| Value chain data collection | Estimation methodology note for value chain data used after the transition |
Common failures
- Gap explanation copied unchanged across all three years with no progress shown
- Estimates used without documented sources or assumptions
Dates
The three years run from the first financial year in which the undertaking is subject to the reporting duty. For a financial year starting 1 January 2027, the period ends with the financial year starting 1 January 2030.
The question to test
Does the statement explain why the information was missing and what the company will do, or does it only say the data was unavailable?
Cross-references
A2-4 Value chain cap · A2-9 Group value chain cap · A2-13 Electronic format
Source
Article 2(4)(b)(i), final subparagraph of Article 19a(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.