Short answer
The answer, before the reasoning
Yes. Paragraph 25 of the Commission-adopted 2026 Voluntary Standard permits an undertaking, after completing B1-B11, to report selected disclosures from the Comprehensive Module. The safest reporting basis is to retain the Option A statement for the completed Basic Module, label the selected C disclosures as supplementary, explain the basis in B1 and show them separately in the disclosure index.
The undertaking should not describe the report as Option B, “partial Option B” or “Option A+” unless it has completed the Comprehensive Module in its entirety. Each selected C disclosure should be reported with its own applicability, voluntary/may and ≤10-employee classifications preserved.
Controlled workflow for selected C disclosures: complete Basic, define the purpose, build evidence, describe the basis and index separately.
Technical status
LEGAL-STATUS NOTE
The European Commission adopted C(2026) 5011 on 3 July 2026. At the source-check date, the Commission status page stated that the delegated act was not in force until publication in the Official Journal. Recheck the final EU number, scrutiny outcome, entry into force and any changed wording immediately before publication.
The source basis
Paragraph 24 says the undertaking reports sustainability issues using B1-B11. Paragraph 25 then states that, once those disclosures have been completed, the undertaking may additionally report disclosures selected from the Comprehensive Module. This is an express permission to add selected C information. It does not create a third reporting option, because B1 paragraph 27 identifies only Option A (Basic only) and Option B (Basic plus Comprehensive).
The practical solution is therefore to separate the formal module statement from the supplementary content. The undertaking applies Option A to the Basic Module and explains that selected C disclosures are included in addition. This describes what the report actually contains without implying that C1-C9 have been completed as a module.
Rule
CORE DISTINCTION
Selected C information is permitted content. Full Option B is a reporting claim about the Comprehensive Module as a whole. Content permission and claim permission are not the same thing.
In practice
When selected C is useful
| Situation | Why selected C may be appropriate | Possible disclosure |
|---|---|---|
| A bank needs transition information for a loan decision. | The user needs target architecture and climate-risk information, not the entire C module. | C3 and C4. |
| A customer asks how sustainability policies cover suppliers. | C2 deepens B2 and can answer the request without a broad Option B project. | C2. |
| An investor or owner asks about human-rights governance. | The undertaking can provide policy/process information while developing other C datasets. | C6 and, where appropriate, C7. |
| A company in a specified activity must respond to a financial-market questionnaire. | C8 may provide a focused revenue datapoint. | C8. |
| The undertaking wants to demonstrate improved data maturity in year two. | Selected C can be a controlled transition step before a later Option B assessment. | Relevant C disclosures, with a clear non-Option-B statement. |
When selected C is not the right answer
The Basic Module is incomplete or the Option A statement is not supported. Paragraph 25 is not a workaround for missing B disclosures.
The undertaking intends to advertise “full Comprehensive reporting” while omitting material parts of C1-C9.
A single datapoint is extracted without the context, trigger, method or limitation needed by the disclosure.
The selected disclosure is not relevant to the user and is added only to make the report look more advanced.
The report does not have a transparent index or basis statement, so readers cannot distinguish formal and supplementary content.
Select at the disclosure level, then test the datapoints inside it
A disciplined selection starts with the numbered C disclosure - for example C3, C4 or C6 - rather than with a convenient individual field. The team should read the full disclosure, identify the trigger and each datapoint classification, and decide what is necessary to represent the disclosure faithfully. This prevents a report from presenting a target value without the base year, scope or main actions, or a human-rights “yes” answer without identifying the issues the policy covers.
In practice
| Selected disclosure | Minimum integrity questions |
|---|---|
| C1 | Are the products/services, markets, relationships and sustainability-related strategy elements described consistently? Which fields are voluntary for ≤10 employees? |
| C2 | Does the description connect to B2, identify supplier/customer coverage, describe targets and avoid confusing policies with actions? |
| C3 | If targets exist, are target year/value, base year/value, units, covered scopes and main actions included? Is transition-plan wording correctly classified? |
| C4 | Do identified hazards or transition events actually create risks? Are exposure/sensitivity, time horizons and adaptation actions described? |
| C6-C7 | Are yes/no answers based on approved policies, mechanisms and confirmed-incident criteria? Are privacy and legal restrictions controlled? |
| C8-C9 | Do the activity/governance triggers apply, and are calculations reconciled to finance or governance records? |
How to describe the basis in B1
B1 requires the selected option and an explicit statement of compliance. Where the undertaking has completed the Basic Module and adds selected C information, the statement should keep Option A as the formal route and explain the additional content. The explanation can sit immediately after the Option A sentence, in a basis-of-preparation note and in the disclosure index.
The wording should be adapted to the final legal title, the actual selected disclosures, the reporting perimeter and any omissions. It should not use “Option A+” as though it were an official label. An internal shorthand may be convenient for project management, but it should not become the public claim.
Hypothetical scenario
ILLUSTRATIVE B1 WORDING
“The undertaking has prepared this sustainability report in accordance with Option A of the EU Voluntary Sustainability Reporting Standard, comprising the Basic Module. In addition, the report includes selected supplementary information from C2, C3 and C4 to address identified information needs of lenders and customers. The undertaking does not state that it applies the Comprehensive Module in its entirety.”
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
Build a transparent disclosure index
Illustrative disclosure index: Basic disclosures and selected supplementary C information are labelled separately.
A useful index contains, at minimum, the module, disclosure identifier, datapoint or topic, classification, applicability, status, exact report location and basis or explanation. For selected C information, use a status such as “supplementary selected C disclosure”. A “not selected” row can be useful in the controlled matrix even if the public index lists only the selected C disclosures, because it preserves the decision trail.
In practice
| Index status | Meaning | Public wording risk |
|---|---|---|
| Reported | A Basic disclosure or datapoint included under the Option A basis. | Do not imply assurance unless separately supported. |
| Not applicable | The stated trigger was assessed and did not apply. | Do not confuse with a paragraph 22 omission. |
| Supplementary selected C | A C disclosure added under paragraph 25 without a full Option B claim. | Do not label “Option B compliant”. |
| Omitted under paragraph 22 | Applicable information withheld under a permitted category and identified in B1. | Requires specific support and reassessment. |
| Not selected | A C disclosure outside the selected supplementary scope. | Do not present the selection as an incomplete Option B module. |
A controlled implementation workflow
1. Finish the Basic Module and approve the provisional Option A basis.
2. Record the user need for every proposed C disclosure. A lender request, procurement criterion or management decision is a stronger basis than a general desire for more content.
3. Read the full C disclosure, identify conditions and voluntary elements, and define the reporting boundary and period.
4. Assign evidence IDs, data owners, methodology, limitations and a reviewer.
5. Draft the selected C section with a visible “supplementary” label.
6. Update B1 and the disclosure index so the formal route and extra information are unmistakable.
7. Run consistency checks across the public report, response pack, web page and questionnaire answers.
8. Approve the claim and selected content together; retain the decision for the next reporting cycle.
Hypothetical example: selected C6 for a customer request
This outcome is defensible because the selected disclosure is relevant, supported and clearly labelled. The undertaking should not answer C7 “no incidents” until it has established the population, confirmation threshold, reporting period and value-chain awareness process needed to support that statement.
Hypothetical scenario
ILLUSTRATIVE SCENARIO
A 90-employee components supplier completes B1-B11. A strategic customer asks whether the supplier has a human-rights policy and complaints mechanism. The supplier has an approved code covering child labour, forced labour, trafficking, discrimination and accident prevention, plus a confidential grievance channel. It includes C6 as a selected supplementary disclosure. It does not include C7 because the customer did not request incident data and the undertaking is still formalising its confirmed-incident protocol. The report remains Option A and the index shows C6 as supplementary.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
Weak and stronger wording
| Weak wording | Why it is weak | Stronger structure |
|---|---|---|
| “We apply Option A+.” | The label is not one of the two B1 options and does not explain the scope. | State Option A, name the selected C disclosures and say no full Comprehensive claim is made. |
| “The report is partially compliant with Option B.” | The whole-module rule makes the phrase ambiguous. | Describe the actual supplementary information without a partial-compliance label. |
| “C3: target 50% by 2030.” | No base year, base value, units, scope or actions. | Present the complete applicable C3 target architecture and method. |
| “C4 not relevant.” | No facts or review trail. | Document the hazard/transition-event screen, exposure conclusion, period and reviewer. |
| “Supplementary information - unaudited.” | The label may imply that Basic information was audited or that review is unnecessary. | Describe the reporting basis; separately state assurance status only if accurate. |
Common errors
Using selected C to compensate for an incomplete Basic Module.
Selecting individual convenient datapoints while omitting the context necessary to understand the disclosure.
Changing the B1 statement in the report but not in the website, customer questionnaire or lender pack.
Failing to preserve ≤10-employee and if-applicable classifications in the selected disclosure.
Calling the information voluntary in a way that suggests it does not need evidence or review.
Leaving the public index unable to distinguish B and supplementary C information.
Allowing selected C content to develop independently from the canonical report and evidence register.
Readiness
Selected C readiness checklist
- B1-B11 are complete and the Option A basis is supportable.
- Each selected C disclosure has a documented user or management purpose.
- The full disclosure and its datapoint classifications have been reviewed.
- Applicability, boundaries, methods, estimates and limitations are documented.
- Evidence IDs and owners are assigned.
- The selected C section is visibly labelled supplementary.
- B1 says the undertaking is not applying the Comprehensive Module in its entirety.
- The disclosure index separates Basic, supplementary C and not-applicable/omitted statuses.
- All external response channels use the same basis statement.
- The selection and claim have final technical approval.
Sources
Primary sources
- · Commission Delegated Regulation C(2026) 5011 final (3 July 2026)
- · Annexes to C(2026) 5011 - Voluntary Standard and value-chain-cap list (3 July 2026)
- · Corporate Sustainability Reporting Directive - implementing and delegated acts (updated 3 July 2026)
- · Commission adopts revised sustainability reporting standards (3 July 2026)
- · Voluntary Standard - interactive text (2026)
- · Directive (EU) 2026/470 (Omnibus I) (24 February 2026)
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