This applies to any company anywhere that supplies into the list of EU companies subject to the Corporate Sustainability Reporting Directive (CSRD).
This silent policy could put your company sales at risk
For American suppliers, Europe’s regulations are an ocean away. Most owners of small firms in Britain have had little time for new Brussels rules (after all, we left the EU!). The view is simple. The rules will not touch us.
That view misses a key fact.
EU buyers have sophisticated supply chains that directly and indirectly includes many thousands of companies that sell into Europe. They still face European laws. When those buyers need data, you – even as a small supplier – will feel the pull.
This Corporate Sustainability Reporting Directive (CSRD) is the latest pull. Many people thought it would hit fifty thousand firms. They also thought every supplier would have to feed data up the line.
Then, in March this year, the Commission proposed to shrink the rule. Only about seven thousand groups will fall under the new draft. Some owners read the headline and breathed out.
They should hold that breath a little longer.
This article sets out why. We will cover three points:
- The real rule that still stands.
- The risk if you ignore it.
- A plain checklist that keeps you safe.
Read on. It may save a tender.
1. The real rule that still stands
The big change in the draft is who must file a public report. Under the old plan, any firm with two of these three tags had to file:
- Two hundred and fifty staff
- Forty million euro turnover
- Twenty million euro assets
Under the new plan, the tags jump to:
- One thousand staff and
- Four hundred and fifty million euro turnover
That is a steep jump. Most mid-sized businesses will step out of the fire line. Yet the story does not end there.
Large firms must still prove they know the impact of their trading chain. They still need solid numbers on carbon, waste, and labour. They still need to show how they cut risk. That means they still need facts from you. Or your business risks getting cut out.
The Omnibus draft also delays the first filing date by one year. That seems like a gift. In truth, it is a hint. The Commission knows that large firms need more time to pull data from suppliers. That time will pass quickly.
NOTE: If you sell parts, food, or services into any group that meets the new size test, you are still part of the file.
You may never put your name on a CSRD document. Yet your numbers will sit inside one. The rule may not chase you. Your buyer will.
2. The risk if you ignore it
Let us picture a simple chain. You make plastic caps in Leeds. You sell them to a bottle plant in the Midlands. The plant sells bottles to a soft drink giant in Germany. The German group clears both size tests. It must file under CSRD.
The group asks the bottle plant for data on energy use and recycle share. The bottle plant turns to you for the same data. You shrug and say, “We are not in the EU. We do not track that.” What happens next?
- You drop on the ranking. Buyers use a points grid on tenders. One line says “Supplier data ready”. Zero points puts you behind at once.
- Rush audits cost more. If the buyer still wants you, it will send an audit team. They will charge. They will spot more gaps when rushed.
- Fines creep into contracts. New EU laws let buyers claim back losses tied to weak links. Clauses appear that dock pay if you fail to give numbers.
- Reputation spreads fast. A firm known to dodge data flags risk. That note can cross to other clients.
You may not break any law. Yet you can still lose work. All because you did not keep a small file up to date.
3. A plain checklist that keeps you safe
Most owners fear green reports because they look huge. You do not need a huge file. You need a neat pack that covers the first tier of questions. One folder, one small policy, a few proof files. That is it.
Below is the checklist. Tick each line before July 2026. Then you can sleep sound.
☐ Map your main inputs List your five biggest materials and five biggest energy uses. One page.
☐ Collect last year’s bills Power, gas, water, fuel. Scan or save PDFs. Keep in one place.
☐ Estimate your carbon Use a free online tool. Enter kWh, litres, miles. Note the tonnes.
☐ Set one modest goal Pick one move. Swap to LED bulbs. Cut waste pickups. Cut fuel by five per cent.
☐ Write a 150-word policy State you track use. State the goal. State you review each year. Keep it plain.
☐ Add one proof file A photo of new bulbs. A waste log sheet. Show real action.
☐ Store all in one folder Name it “Sustainability Pack 2025”. Use cloud share for quick links.
☐ Mark a diary date First of June each year. Update numbers. Add a new proof file.
Follow each step. You spend one quiet day. You save days of panic later.
How the checklist helps you stand out
Speed on tenders When a buyer sends a data request, you reply at once. You fill forms in an hour. Others need weeks.
Lower audit fees A clear file means fewer site checks. Auditors spend less time on you. Cost stays down.
Better client talk You can show progress year on year. Even simple graphs make the point. Buyers like clear, steady data.
Staff morale Team members see the goal and help cut waste. Small wins build pride.
None of this calls for big spend. Most firms can reach the first two years of targets with simple swaps. LED bulbs, light sensors, better truck routes. The gains often pay for themselves.
What to do this week
- Open a fresh folder on your drive. Call it Sustainability Pack.
- Book two hours with your office manager. Gather the bills.
- Pick one online carbon tool. Many are free.
- Draft the short policy. Use plain language.
- Pick a first goal that you can meet within twelve months. Keep it modest.
- Set a reminder for one year minus a week. That is your yearly check.
Do this now. By the time CSRD files start to flow, you will look ready.
A note on the Omnibus timeline
The draft still needs a vote in Parliament. Debate may push small changes. The core jump in size tests is likely to stay. The extra year is almost certain. Do not wait for the final vote. Early movers gain trust. Late movers pay more.
Closing thought
Brexit did not cut the links that bind our sales to Europe. Every month, rules like CSRD tighten the grip on those links. You can fight each rule. Or you can keep a lean file and turn the rule to edge out slow rivals.
Spend one day. Build the folder. Tick the list. Then get back to serving clients with one less worry.
If you want a template of the folder with sample files, let me know in the comments. I will be glad to share.