CSRD is coming for your supply chain

Shipping containers stacked at a port, representing global supply chains

The Corporate Sustainability Reporting Directive is already law in the EU. Large companies began reporting under it in 2024. The second wave, covering smaller listed companies, was due to follow in 2025 — but EU legislative delays have pushed implementation further out, with the omnibus reforms proposing a two-year deferral. The direction of travel hasn’t changed. Only the timeline has.

This is the part that catches UK businesses off guard.

You don’t have to be an EU-based company to be affected by the CSRD. You just have to be in someone’s supply chain who is. When your customer’s sustainability team asks for your Scope 3 emissions data – and they will – what happens if you don’t have it? In the best case, you lose the contract to a supplier who does. In the worst case, you become a liability in their regulatory filing.

Scope 3 is where most of the carbon is. It is also where most of the uncertainty is. Estimated figures, incomplete methodologies, and data collected from suppliers who are themselves guessing. That was tolerable when reporting was voluntary. It is no longer.

The question isn’t whether your supply chain carbon data will be scrutinised. It’s whether you’ll be ready when it is.