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CSRD and SME suppliers 2026: how to answer your client

By Dr Souha Bel Haj Messaoud | Founder, Eco Fluent Solutions Updated: August 2026 | Reading time: 13 min


Your large-group client sent you a CSR questionnaire. Or asked you to complete a form on its Scope 3 emissions. Or its purchasing team forwarded a list of questions on your environmental policy, working conditions, and purchasing practices.

You are wondering where this is coming from, what is actually expected of you, and how to answer without spending three weeks chasing information scattered across the organisation.

This guide answers those three questions. Directly, with concrete steps to organise your data and respond efficiently.

 

One essential point before you start:

the CSRD (Corporate Sustainability Reporting Directive: the European directive on corporate sustainability reporting) does not apply directly to SMEs. You are not legally required to produce a sustainability report. Your large-group client is. And its obligations extend to its value chain, which includes you.

 


Why your large-group client is asking for this information

CSRD in a few words

CSRD is a European directive that requires large companies to publish a detailed sustainability report covering their environmental, social and governance (ESG: Environmental, Social, Governance) impacts. It replaces and significantly expands the previous non-financial reporting directive.

Companies in scope of CSRD must apply the ESRS (European Sustainability Reporting Standards) to structure their report. These standards cover climate change, biodiversity, water resources, workforce, human rights, governance and business conduct.

 

What CSRD requires on the value chain

This is where you enter the equation.

The ESRS require large companies to report not only on their own activities, but on their entire value chain: upstream suppliers and downstream customers. Greenhouse gas (GHG) emissions from suppliers, social practices in the supply chain, biodiversity risks at subcontractors. All of that sits inside your client’s reporting boundary.

In plain terms: your client cannot produce a complete CSRD report without data that comes from you.

 

To understand what Omnibus I changed for French SMEs: Omnibus I is in force: what French SMEs must do now

 

Omnibus I: what changed and what did not for SMEs

In April 2026, the Omnibus I directive (Directive EU 2026/470) entered into force. It reduced the direct scope of CSRD: fewer companies are now directly required to report.

That does not mean pressure on SME suppliers has disappeared. The large companies that remain in CSRD scope, and there are still many of them, still need value-chain data. Their Scope 3 reporting obligations (indirect emissions linked to suppliers and customers) were not removed.

The pressure you feel from clients is not a fad. It is a structural consequence of their legal obligations, and it will last.

 


What your client is actually asking for

The most frequently requested information

Requests vary by client and sector, but some items come back systematically:

On the environment:

  • Your energy consumption (electricity, gas, fuel oil) and how it is evolving
  • Your direct GHG emissions (Scope 1: emissions from your own activities) and energy-related indirect emissions (Scope 2)
  • Your waste generation and recovery rates
  • Whether you have an environmental policy or a certification such as ISO 14001

On social issues and working conditions:

  • Your workplace accident rate and health-and-safety policy
  • Your training and skills-development practices
  • Whether you have a non-discrimination and equal-opportunity policy
  • Any ISO 45001 certification (occupational health and safety)

On ethics and governance:

  • Whether you have a code of conduct or ethics charter
  • Your anti-corruption practices
  • Your personal-data protection policy

On your own purchasing:

  • Whether CSR criteria exist in your supplier selection
  • CSR clauses in your purchasing contracts

 

Formats and tools used by large groups

Your client may send these requests in different forms:

  • A proprietary questionnaire: developed internally by its purchasing or CSR team
  • A third-party platform: EcoVadis, Ecodesk, Sedex, or other supplier-assessment tools
  • A structured Excel file: often used to collect quantitative data
  • A Scope 3 questionnaire: focused specifically on your GHG emissions to feed your client’s carbon inventory

Whatever the format, the information requested stays largely the same. The difference is presentation and the level of detail expected.

 

Do you regularly receive ESG questionnaires from clients? Read: ESG questionnaires: why SMEs can no longer keep up

 


How to organise your data to respond: a practical guide

Step 1: Understand what is really being asked

Before you start gathering data, read the request carefully. Identify:

  • Which themes are covered (environment, social, ethics, purchasing)
  • Which indicators are requested (quantitative data, written policies, certifications)
  • The expected level of detail (is a yes/no answer enough, or do you need to attach documents?)
  • The response deadline

This first reading stops you hunting for information that was never requested, and missing what actually was.

 

Step 2: Identify the data you already have

Before concluding that you lack the required information, inventory what already exists in the organisation:

  • Accounting and invoices: energy invoices let you reconstruct annual consumption
  • Human resources: training registers, workplace accident data, headcount and gender balance
  • Purchasing: general purchasing conditions, list of main suppliers
  • Quality / HSE: the DUER (Document Unique d’Évaluation des Risques, mandatory for all French companies), safety procedures, existing certifications
  • Management: any internal policy document, even informal

In most cases, SMEs have more relevant information than they think. The problem is not the absence of data. It is that data is scattered across teams and insufficiently formalised.

 

Step 3: Structure your answers with the VSME

The VSME (Voluntary SME Standard: a voluntary ESG reporting standard for SMEs) is a framework developed specifically to help SMEs structure sustainability data. It is not mandatory, but it is designed for exactly the type of requests you receive from large-group clients.

The VSME offers two modules:

  • Basic module: a minimal set of indicators covering the essential themes
  • Narrative module: qualitative information on your approach and policies

Using VSME as the reference frame for your answers has two practical benefits: you avoid starting from scratch with every new client questionnaire, and you can produce one structured document to share with several clients at once.

 

Understand how VSME can become your CSR steering tool: VSME is not another report: a management tool for SME leaders

 

Step 4: Formalise what is not written down yet

For some questions, you will have no document to attach, not because the practice does not exist, but because it has never been written down.

A few simple documents to formalise first:

  • A one-page environmental policy: your commitments on energy, waste and emissions
  • A code of conduct or ethics charter: expected behaviour, your position on corruption
  • CSR clauses in purchasing conditions: one or two sentences are enough to start
  • A dashboard of key indicators: energy consumption, waste, workplace accidents; even partial data is better than none

Formalisation does not need to be perfect. It needs to be honest, consistent, and adapted to the reality of your company.

 


The most frequent SME mistakes on CSRD requests

Waiting until you have everything before answering.

The natural reflex is to want every answer before submitting. In practice, that leads to missed deadlines and last-minute rushed responses. It is better to answer honestly with the data you have, and flag the indicators you plan to measure next, than to send an empty or late questionnaire.

 

Treating each client questionnaire as a one-off.

If you have five large-group clients, you will receive five different questionnaires. Handling each one from scratch is exhausting and inefficient. The solution is a central document base, a reference CSR file, that you adapt to each questionnaire instead of recreating it.

 

Not checking consistency across answers.

Declaring a waste-reduction policy in one section and saying you do not track environmental indicators in another creates an inconsistency your client will notice. Before submitting, reread the full set of answers as one block.

 

Confusing effort with results.

Your clients are not looking for whether you are making an effort. They are looking for measurable data. “We are committed to the environment” is not an answer. “Our energy consumption fell by 8% between 2024 and 2025” is. Even imperfect, a figure is worth infinitely more than a statement of intent.

 

Ignoring the request, or answering the minimum for lack of time.

CSR pressure in value chains will not ease. A rushed answer today sets a precedent, and your client will come back next year with the same expectations, or higher ones. Investing in a structured answer this year is an investment for every year that follows.

 


What happens if you do not answer?

You are not legally sanctioned for not answering a client’s CSR request. The commercial consequences are real, and they are growing.

Large groups in scope of CSRD are assessed on the quality of their value-chain reporting. A supplier that does not answer is, in their system, a risk supplier. Possible consequences:

  • Downgrade in the supplier panel: you move from preferred supplier to alternative supplier
  • Exclusion from tenders: some large groups explicitly condition supplier selection on a minimum CSR score
  • Increased commercial pressure: competitors who answer correctly gain a growing differentiating advantage
  • Lost contracts at renewal: as supplier panels are rationalised, the CSR criterion weighs more and more

This is not about morals or activism. It is about medium-term commercial competitiveness.

 


Frequently asked questions on CSRD and SME suppliers

Is my SME directly in scope of CSRD?

Probably not. CSRD as amended by Omnibus I (2026) applies mainly to large companies above certain size thresholds. SMEs below those thresholds are not directly required to produce a CSRD-compliant sustainability report. They do, however, face indirect pressure as suppliers of large companies that must report on their value chain.

 

Can my client contractually require me to answer?

Yes. More and more large groups include CSR clauses in supplier contracts. Those clauses can require you to provide sustainability data, reach a minimum score on an assessment platform, or comply with specific standards. Check your contract terms: if such clauses exist, your obligation is contractual.

 

What is the link between EcoVadis and my client’s CSRD requests?

EcoVadis is one of the tools some large groups use to collect and assess supplier CSR data. Completing EcoVadis and answering your client’s CSRD requests are two distinct exercises, but they draw on the same underlying information. A well-structured CSR file lets you answer both efficiently.

 

Where do I start if I have nothing in place?

Start with data that already exists in the company: energy invoices, workplace accident register, purchasing conditions. Then formalise the three most requested documents: an environmental policy, a code of conduct, and a dashboard with two or three key indicators. Those four steps can be done in a few weeks and form a solid base for most client questionnaires.

 

Do large groups recognise VSME as a response format?

VSME is a European standard backed by professional organisations and business federations. Recognition by large groups is still developing. In practice, a document structured to VSME will let you answer the large majority of client questionnaires, even if the client does not explicitly ask for VSME. The format matters less than the information it contains.

 

Do I need a third party to verify my CSR data?

For an SME supplier, third-party verification of CSR data is generally not required at this stage. What clients ask for is transparency and consistency, not necessarily formal assurance. Third-party verification becomes relevant if you are targeting specific certifications or if your large-group client requires it explicitly in its contract terms.

 


Ready to structure your answers to client CSR requests?

CSR pressure on SME suppliers is real, growing, and not about to stop. It is manageable — if you respond with a method instead of chasing every questionnaire at the last minute.

At Eco Fluent Solutions, I support SMEs in structuring their CSR data and building a reusable document base — to answer large-group clients, EcoVadis, and any other value-chain request efficiently.

Open Digital Solutions — practical training and resources to structure your CSR approach and meet client requirements.

Download the free CSR checklist — the 20 pieces of information to have before any client questionnaire.


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Dr Souha Bel Haj Messaoud is the founder of Eco Fluent Solutions, a Paris consultancy specialised in ISO management systems, CSR governance and ESG compliance. She supports French and European SMEs in structuring their sustainability data and answering the CSR requirements of their large-group clients. Learn · Comply · Lead — ecofluentsolutions.com