Key takeaways
- CSRD is already reshaping sustainability reporting, with strict requirements and increasing expectations across supply chains.
- Scope 3 and value chain data remain the most challenging elements, making supplier engagement essential.
- EU and UK companies with EU operations must prepare now, with reporting expected from 2029 (FY 2028).
- Supplier expectations will rise, even where suppliers are not legally in scope.
- CSRD readiness is becoming a systems question, not just a reporting question
- Avetta helps organisations streamline supplier data capture, reduce burden, improve response rates, and prepare audit ready CSRD aligned outputs.
We keep hearing variations of the same thing from the sustainability leaders we speak to: “We know CSRD is coming – instead of waiting, we are building the data governance and reporting system now."
It makes sense that we’re continuing to hear this from companies. The Corporate Sustainability Reporting Directive (CSRD) marks one of the most significant shifts in corporate transparency in recent years. Designed to bring sustainability reporting in line with the rigour of financial reporting, CSRD introduces clear, mandatory reporting requirements across environmental, social, and governance (ESG) areas. It’s no longer a voluntary exercise or a “nice‑to‑have”. Compliance is becoming a baseline expectation for businesses operating in or trading with the EU.
If you’re responsible for ESG, procurement, HSE or sustainability, CSRD changes what’s expected of you — fast.
Reporting is becoming more rigorous, more auditable, and more dependent on supplier data. The question isn’t whether to prepare, but how to do it efficiently and with confidence.
For procurement, Environmental, Social, and Governance (ESG), and sustainability teams, the message is clear: supplier data is at the heart of CSRD compliance. Scope 3 emissions, labour practices, human rights risks, and value chain impacts make up some of the largest and most challenging reporting areas, and they depend heavily on accurate, structured supplier information. For example, Scope 3 emissions – those in an organisation’s value chain but not under their direct control - are known to make up 75 - 95% of most companies’ overall carbon footprints. Without supplier information, companies are flying blind.
Recent negotiations between the Council of the EU and the European Parliament have introduced simplifications aimed at reducing reporting burdens (Omnibus), but these changes do not reduce the strategic importance of robust, auditable ESG data. Businesses will still need strong systems, reliable supplier engagement, and clarity across their supply chains.
Who’s in scope for CSRD?
Understanding whether your organisation falls in scope is the first (and often most confusing) step. Here’s how the requirements break down.
EU based companies
Under the simplified thresholds agreed by EU lawmakers, CSRD applies to large EU companies that meet:
- 1,000+ employees, and
- €450M+ annual turnover.
Listed SMEs have been removed from mandatory scope for now, though many will still feel indirect pressure to report due to customer expectations. Transitional exemptions apply to “wave one” reporters who began reporting in 2024.
Non EU companies, including the UK
Non EU parent companies — including those in the UK — fall within CSRD when they generate €450M+ turnover in the EU. UK companies with EU branches or significant EU operations are expected to begin reporting in 2029 for FY 2028.
Suppliers and SMEs: The indirect scope
Suppliers are not legally required to produce full CSRD reports. However, they will continue to receive data requests from in scope customers seeking Scope 3, human rights, and ESG related information.
The VSME (Voluntary Standard for SMEs, sometimes called the VS or Voluntary Standard) is becoming the default baseline, helping suppliers align with CSRD expectations without the burden of the full ESRS.
What CSRD requires: Key disclosures and reporting expectations
CSRD reporting is governed by the European Sustainability Reporting Standards (ESRS), covering:
- Environmental topics (including climate, pollution, circularity, biodiversity)
- Social topics (workforce, value chain workers, affected communities, consumers)
- Governance topics (conduct, controls, business ethics)
A central requirement is double materiality analysis; assessing both how sustainability issues impact the company financially and how the company impacts society and the environment. Procurement teams play a central role by supplying the insights required for value chain assessments.
CSRD demands auditable, evidence backed data, and this elevates the importance of structured supplier information. Your company will need to gather:
- Scope 1, 2, and especially Scope 3 emissions
- Human rights, modern slavery, and labour conditions insights
- ESG policies, governance data, and risk indicators
What ESG and procurement teams need to do now for CSRD
Here are some practical tips to start bringing into your reporting.
- Start by mapping whether your organisation is in scope: Assess entity size, turnover, and your EU footprint. UK organisations should identify all EU subsidiaries or branches to understand early obligations.
- Prepare for (or support) double materiality: Materiality determines which ESRS topics apply. Procurement plays a critical role by identifying exposure across the value chain.
- Identify supplier data requirements: The supply chain is often the most complex and time consuming source of CSRD data, but Avetta can help companies determine the right data to request from suppliers to fulfil CSRD requirements. Required supplier information includes:
- Scope 3 emissions
- Human rights and modern slavery
- Labour conditions and worker safety
- Environmental management practices
- Pollution
- Resource use and circular economy
- Build (or strengthen) supplier engagement strategies: To meet CSRD timelines, organisations must begin supplier engagement early. This means bringing together;
- Clear communication of expectations
- Templates, training, and standardised assessments
- Using Voluntary Sustainability Reporting Standard for Non-Listed SMEs (VSME) as a harmonised baseline
- Implement systems for audit ready reporting: Manual spreadsheets and ad hoc engagement will not meet CSRD’s assurance requirements. Teams need systems capable of structured data capture, reliable evidence management, and governance and audit trails
Common gaps and risks (and how to avoid them)
Even organisations with established sustainability frameworks can hit roadblocks when preparing for CSRD. Most of these challenges stem from the increasing dependence on value chain data, which is, by nature, fragmented, inconsistent, and outside direct corporate control. Understanding these risks early is essential to staying audit ready and maintaining momentum.
Supplier pushback: “We are not legally in scope”
This is one of the most common forms of friction. Many suppliers — particularly smaller organisations — assume that because they are not legally required to report under CSRD, they shouldn’t be expected to supply ESG data at all.
In reality, CSRD reporting companies must disclose Scope 3, human rights, labour, and environmental impacts across their entire value chain. That means suppliers play a critical role in enabling compliance.
Without clear communication, suppliers can become disengaged or resistant, delaying data collection efforts and leaving material gaps in your reporting.
How to avoid it:
- Be transparent about why the data is needed and how it directly impacts your reporting obligations.
- Offer standardised, VSME aligned assessments to reduce burden.
- Provide supplier training, FAQs, and support channels to make participation easier.
- Start early — momentum here makes everything else easier.
Low supplier response rates (especially among SMEs)
Small and medium sized suppliers often lack the resources, understanding, or internal systems to respond effectively to ESG data requests. Many are juggling multiple questionnaires from different customers and may prioritise those with the clearest expectations and easiest processes.
Without high response rates, companies struggle to build an accurate value chain impact profile, undermining both CSRD disclosures and broader sustainability commitments.
How to avoid it:
- Use a centralised, user friendly data collection system that reduces duplicate requests.
- Communicate early and consistently, reinforcing deadlines and expectations.
- Provide suppliers with simplified forms, prefilled data where possible, and helpdesk support.
- Monitor response progress and follow up with human led engagement — not just automated reminders.
Incomplete or inaccurate Scope 3 data
Scope 3 emissions remain one of the most difficult areas for organisations to measure, validate, and standardise, even though they make up the majority of a company’s emissions. Missing, estimated, or inconsistent data increases the risk of inaccurate disclosures and weakens the organisation’s ability to demonstrate progress.
Many suppliers lack emissions tracking capabilities and rely heavily on assumptions or outdated methodologies. This presents a major risk to CSRD assurance, which requires evidence backed, traceable data.
How to avoid it:
- Standardise the process with structured ESG and carbon disclosure forms.
- Support suppliers with education, guidance, and easy‑to‑use calculators or tools.
- Prioritise high impact suppliers first, based on spend, geography, or emissions relevance.
Inconsistent or unverifiable evidence
Auditors require traceability. Many organisations rely on manual spreadsheets, ad hoc supplier engagement, or email based data collection — all of which increase the likelihood of inconsistent data formats, missing documentation, and unclear audit trails.
Unverifiable data creates compliance risks and can lead to findings of non‑conformance during assurance reviews. It also undermines internal confidence in sustainability metrics.
How to avoid it:
- Implement a system built for audit ready reporting with structured evidence capture.
- Ensure suppliers upload documentation directly rather than embedding it in emails.
- Use validation levels (self reported, evidence backed, third party verified) to clearly signal data quality.
- Maintain a single source of truth rather than department level spreadsheets.
Lack of alignment across ESG, procurement, finance, and legal teams
CSRD is cross functional by design, but many organisations still operate in silos.
Procurement collects supplier information, ESG teams interpret it, finance consolidates disclosures, and legal reviews compliance implications. When these groups aren’t working cohesively, reporting becomes slow, fragmented, and error prone.
This misalignment often results in duplicate supplier requests, conflicting instructions, and unclear ownership of key elements of CSRD preparation.
How to avoid it:
- Establish clear responsibilities and shared KPIs for CSRD related activities
- Create cross functional working groups to coordinate supplier engagement and data needs
- Align communication to suppliers so they receive consistent messages and expectations
- Adopt platforms that centralise data and reduce reliance on siloed workflows
Why these gaps matter
These challenges aren’t minor administrative hiccups. They can:
- Delay reporting timelines
- Lead to non‑compliance or failed assurance
- Undermine sustainability credibility
- Increase reputational and regulatory risk
- Create supplier friction that slows progress across the business
CSRD expects structured, transparent, and verifiable value chain data — and that means organisations must close these gaps before reporting deadlines approach.
With the right systems, communication strategies, and cross functional alignment, the most common risks can be significantly reduced, paving the way for consistent, audit ready disclosures.
How Avetta helps organisations meet CSRD requirements
We help organisations to work towards CSRD readiness by delivering the supplier level data, structured workflows, and evidence backed insights organisations need to meet their disclosure and assurance obligations with confidence.
Collecting supplier data aligned to CSRD and ESRS
To meet the heightened expectations of CSRD and the ESRS framework, organisations need supplier data that is structured, accurate, and consistently verifiable. Our platform makes this possible by transforming what is typically an overwhelming, fragmented process into a clear, streamlined experience for both procurement teams and their suppliers.
We help you collect supplier data in a structured, consistent way — so your reporting is clearer, faster, and ready for audit:
- Carbon disclosure (Scope 1, 2, and 3): Capturing emissions data at the supplier level — whether estimated or evidence backed — gives organisations the insight needed to build reliable Scope 3 inventories and strengthen climate related disclosures.
- ESG policies and practices: Using evaluations built on global ESG frameworks, suppliers can report on policies, governance processes, and sustainability commitments in a consistent format that aligns with CSRD’s disclosure requirements. These expert built assessments help standardise reporting across a diverse supplier base.
- Modern slavery and human rights: With clear, targeted questions tailored to supplier size and risk profile, organisations can capture data on labour standards, ethical practices, and human rights safeguards throughout the value chain — a core component of ESRS S1–S4 reporting. This visibility is crucial for identifying potential adverse impacts early.
- Health and safety: Our longstanding strength in safety performance and compliance helps organisations gather the safety data required under CSRD’s social and governance topics. This includes documentation of safety processes, certifications, and incident history — all structured to support cross functional reporting needs.
By using consistent assessments and a centralised data model, organisations avoid the pitfalls of disparate spreadsheets, manually collated evidence, and one off questionnaires.
Evidence backed and verification tiered data ensures audit readiness, giving teams confidence that the information they’re submitting is complete, traceable, and aligned to assurance expectations. This makes it easier to demonstrate progress against sustainability targets, respond to auditor queries, and maintain a defensible compliance posture.
Reducing supplier burden
Navigating ESG and CSRD aligned requests can feel overwhelming for suppliers — especially those without dedicated sustainability teams or established reporting processes. Our platform makes this easier by removing complexity at every step and giving suppliers the clarity, structure, and support they need to respond confidently.
We support suppliers through:
- Preconfigured forms: Designed by our ESG specialists and aligned to widely recognised standards, these forms ensure suppliers only answer the questions relevant to their size, sector, and risk profile — reducing duplication, guesswork, and time spent interpreting requirements.
- Playbooks and guidance: Suppliers gain access to clear, practical resources that explain what’s being asked of them and why it matters. These playbooks break down complex topics into simple actions, helping suppliers understand expectations, prepare the right evidence, and progress at their own pace.
- In platform help and helpdesk support: With intuitive prompts, FAQs, and step‑by‑step guidance built directly into the platform, suppliers never have to navigate the process alone. And when personalised help is needed, our responsive helpdesk teams are available to resolve queries quickly and keep submissions on track.
Improving supplier response rates
Securing timely, complete responses from suppliers is one of the biggest hurdles in CSRD preparation, especially when teams rely on manual outreach or fragmented systems. We help your organisation overcome this by creating a streamlined, predictable experience that suppliers trust and are more willing to engage with.
With historically higher supplier participation than general ESG platforms, our combination of structured workflows, smart automation, and human‑led support removes friction at every stage. Suppliers receive clear, relevant requests — not generic questionnaires — which helps reduce fatigue and boosts willingness to respond.
See improved response rates and data quality through:
- Purpose‑built workflows that guide suppliers step-by-step: Intuitive task flows help suppliers understand exactly what is required of them, when it’s due, and how to complete each step. This reduces confusion, rework, and back‑and‑forth communication.
- Automated reminders that feel supportive, not intrusive: Timely nudges keep suppliers on track without overwhelming their inboxes. Reminders are designed to reinforce clarity, reduce missed deadlines, and maintain momentum, especially across large supplier populations.
- Human led engagement when suppliers need extra support: When suppliers stall or struggle, our engagement teams step in with one‑to‑one guidance, practical explanations, and real time troubleshooting. This personalised support is often the difference between partial data and complete submissions.
- A friction free platform that simplifies the entire process: By offering a single place to upload documents, respond to ESG assessments, and track progress, suppliers avoid the overwhelm of multiple systems and inconsistent requests — a key driver of higher completion rates.
The result is a smoother, clearer experience for suppliers and stronger, more reliable data for your CSRD disclosures, helping your organisation move from chasing responses to confidently reporting on the value chain impacts that matter most.
Delivering audit ready outputs
We're helping organisations turn supplier level information into clean, consistent, and defensible outputs that reduce audit friction and strengthen reporting confidence.
Our reporting tools include:
- Exportable CSRD relevant reports: Your organisation can quickly generate structured reports that consolidate supplier data into CSRD aligned formats, making it easier for your ESG, finance, and audit teams to review, validate, and integrate disclosures without manually cleaning or reformatting information. These exportable reports support internal governance, external assurance, and cross functional collaboration by ensuring everyone works from the same verified data foundation.
- Dashboards with CSRD aligned indicators: Real time dashboards give your teams visibility into the metrics that matter, from supplier carbon disclosures to ESG policy adoption, human rights indicators, and modern slavery risks. CSRD aligned views make it easier to identify gaps early, monitor progress across reporting cycles, and provide leadership with transparent, decision ready insights. These dashboards are particularly effective for tracking progress against ESRS topics and strengthening internal accountability.
- Validation levels for assurance consistency: To support CSRD’s requirement for externally assured data, we apply validation tiers that clearly signal the confidence level of each data point, whether it’s self reported, evidence backed, or independently verified. This structured approach supports smoother assurance processes, reduces follow up cycles with auditors, and helps you to demonstrate due diligence across your entire value chain.
Together, these capabilities give your organisation a reliable, centralised system for producing audit ready outputs, ensuring teams can move into each CSRD reporting cycle with confidence, clarity, and fewer last minute surprises.
Supporting CSDDD & due diligence
As due diligence expectations rise globally — and with the Corporate Sustainability Due Diligence Directive (CSDDD) introducing more structured requirements for identifying, preventing, and mitigating adverse impacts — your organisation needs reliable visibility into supplier level risks. We support these broader ESG due diligence efforts by giving your teams the tools and insights required to act early, stay aligned across functions, and demonstrate a clear, evidence based approach to responsible business conduct.
- Supplier risk identification: We help your organisation spot potential risks across environmental, social, human rights, and governance areas by consolidating supplier information into a single, consistent view. Risk indicators such as policy gaps, safety performance trends, modern slavery red flags, and geographic exposure can be assessed early, making it easier to prioritise suppliers for further review or engagement.
- Evidence collection: Effective due diligence depends on verifiable documentation. We provide a structured, traceable way for suppliers to submit evidence — from ESG policy documents to certifications, declarations, and supporting materials — ensuring your organisation can maintain a defensible record of the steps taken to assess and respond to risks. Clear validation tiers also helps your teams understand the strength of each data point.
- Monitoring changes over time: Due diligence isn’t a one off exercise. Our platform helps your organisation track how suppliers evolve — whether they improve, stall, or introduce new risks. Continuous monitoring of updates, expired evidence, policy changes, audit outcomes, and alerts enables your teams to respond proactively and maintain consistent oversight across the supply chain.
Together, these capabilities help your organisation build a more resilient, transparent, and ethically aligned value chain. We equip your teams with the insight and structure needed to embed due diligence into everyday operations — supporting responsible sourcing, stronger supplier partnerships, and readiness for evolving regulations like CSDDD.
What’s next?
CSRD reporting windows are already in motion for many businesses, and supplier data collection is often the longest and most complex stage. Starting early (like many of the leaders we keep hearing from), engaging suppliers clearly, and building reliable data systems will be key to compliance success.
If you’re ready to simplify supplier data collection and strengthen audit readiness, we’re here to help.
