Many companies that fall outside the CSRD’s scope as a result of the EU Omnibus are finding that the pressure from their supply chain does not disappear with it. Customers, parent companies and banks keep sending ESG questionnaires – on CO₂ emissions, working conditions, governance and supply-chain due diligence. As a supplier or partner, you may not be required to report on these topics, but if you want to maintain the relationship with your key partners, they are hard to ignore.
The Omnibus package established that only companies with more than 1,000 employees and a turnover above €450 million still fall under the CSRD. As soon as you stay below either threshold, you are not required to report yourself. But if your customers are, you are drawn into the CSRD story all the same.
Wave 1 companies (listed companies and large financial institutions) have already reported on financial years 2024 and 2025. Wave 2 companies are now preparing for their first mandatory report – on financial year 2027. For both groups, ESG data from the value chain is essential, which translates into specific questions for their supply-chain partners.
These questions take various forms. Some companies ask for an EcoVadis assessment, or send a CDP questionnaire or a supplier code of conduct. They may also take the form of specific data requests from individual customers, such as large retailers.
They usually concern the following topics:
• scope 1, 2 and, increasingly, scope 3 emissions
• water and material use, waste streams, packaging and circularity, and impact on biodiversity
• working conditions, pay equality, health and safety, and so on
• governance, responsibilities and policies
• due diligence in your own value chain
The questions become more detailed every year. The ESG data of companies subject to the CSRD is reviewed by an auditor, and vague, incomplete or inadequately substantiated supplier data can lead to audit findings.
In this way, the audit of a CSRD report reaches deep into the value chain.
Many companies answer every questionnaire separately, over and over again. If you receive varying questions from different parties each year, that leads to inconsistency and inefficiency. And because the questions keep growing, a system that is just about workable today will no longer suffice in two years.
To prepare strategically for pressure from the supply chain, you don’t need to produce a full CSRD report. A single core infrastructure for customer questions is what makes the difference.
You build this infrastructure in three steps:
1. Take stock of which ESG data your customers request, and where in your organisation that information is available.
2. Link your KPIs to a consistent measurement methodology. For example, if you document once how you calculate your CO₂ emissions, you have a basis to fall back on each year or each quarter.
3. Establish clear internal ownership. Once it is settled who owns which data, you no longer start from scratch with each new questionnaire.
If you also receive questions about your own suppliers’ practices, it pays to pass them down your own supply chain – and to gather information from them in good time.
If you truly want to stand out, data alone is not enough.
Companies that answer ESG questions quickly and convincingly usually tell a clear story about who they are when it comes to sustainability, what they do and why – a story that ties their efforts and KPIs into a single whole.
Small and medium-sized companies often have a key asset here: authenticity. A family business that has been investing for 20 years in, say, local roots and energy saving tells just as valuable a story as an industrial company documenting its transition to circular production.
That distinctiveness gives ESG data meaning and makes questionnaire answers consistent and credible.
Companies that invest in ESG data and processes today are also stronger in other areas:
- with banks and investors, for whom ESG performance is increasingly a criterion;
- in attracting and retaining employees and candidates, for whom sustainability performance plays an ever-greater role;
- when the CSRD thresholds shift again – adapting is easier from an existing foundation.
But the most direct return is commercial. Customers subject to the CSRD prefer suppliers that can answer ESG questions clearly, consistently and quickly.
If you want to avoid time pressure and build a competitive advantage, develop this foundation today. Without a CSRD obligation you have no external deadline, but your customers do – and their preparation will mobilise the entire supply chain.
Would you like to collect ESG data in a structured way, answer questionnaires more efficiently and stand stronger with customers, banks and other stakeholders? Then opt for sustainability reporting based on the VSME, a proportionate framework developed for SMEs. We help you determine what makes sense and set up the process for you.
Discover our offering: Voluntary reporting (VSME)
Or contact us directly at mail@pantarein.be.