When the European Union (EU) finalized its Omnibus I simplification package in February 2026, most of the coverage focused on who had been let off. Directive (EU) 2026/470 has narrowed the Corporate Sustainability Reporting Directive (CSRD) to companies with more than €450 million in net turnover and more than 1,000 employees, and the revised reporting standards that followed have cut what those companies have to report considerably.
The rules also reach beyond Europe: companies headquartered elsewhere are covered if they generate more than €450 million in EU turnover and have an EU subsidiary or brand with more than €200 million, with their first reports due from 2029.
Less attention has gone to what stayed the same. The part of the CSRD that depends on supplier data has changed much less, and the new rules leave companies more reliant on their suppliers' willingness to share. EU member states have until March 19, 2027 to bring the changes into national law, and companies that haven't yet started reporting will report on financial years starting from January 1, 2027, with their first reports due in 2028, which leaves little time to get those supplier relationships in place.
What the revised standards keep for Scope 3
In July 2026, the European Commission adopted revised European Sustainability Reporting Standards (ESRS), which apply to financial years starting on or after January 1, 2027 and cut mandatory datapoints by more than 60% and total datapoints by more than 70%, with reporting costs expected to fall by over 30% per company.
Companies that assess climate change as a significant issue for their business still report gross Scope 3 emissions for each of their main categories, and those that decide it isn't have to explain why. Which categories count is judged on their estimated size alongside factors such as spend and the company's influence over them, with that list reviewed every year and the full inventory at least every three years.
Greenhouse gas emissions are also the only metric in the topic-specific standards that has to extend into the value chain, and they are excluded from a relief that lets companies report other metrics for only part of their operations or value chain.
A cap on what companies can require
The change with the most direct effect on supplier relationships is the value chain cap. From financial years starting in 2027, companies in scope of the CSRD cannot require suppliers with 1,000 or fewer employees to provide information beyond a short list of essential datapoints set out in a new voluntary reporting standard. The revised ESRS apply the same limit to suppliers based outside the EU.
The list is short on climate data. For suppliers with more than 10 employees, it covers total energy consumption and estimated gross greenhouse gas emissions, and for those with 10 or fewer it covers no climate information at all. Neither group can be required to share reduction targets or plans.
The cap only covers information a company collects for its own CSRD reporting, and it doesn't restrict requests needed to comply with other EU or national law, so data gathered for the Carbon Border Adjustment Mechanism (CBAM), for example, sits outside it. It limits what a company can require, so suppliers can still choose to share more when the relationship gives them a reason to.
Transition plans still have to show how emissions will fall
The revised climate standard keeps the existing requirement for companies to explain how their reductions will happen. Value chain information can come directly from suppliers or from estimates built on sector averages and spend-based data, and for their first three years of reporting, companies that can't obtain everything they need can instead explain what they have done to get it and how they plan to close the gap.
What counts as reasonably available information is reassessed every reporting period, and the standards state that the availability of information "is expected to improve over time." The climate standard points the same way, asking companies to prioritize primary data from activities in their value chain when they calculate Scope 3.
The rules therefore limit what companies can demand from smaller suppliers while expecting the quality of supplier data to improve year on year. Closing that gap depends on supplier relationships strong enough that suppliers choose to share more than the minimum, and few programs are there yet. In the Scope 3 Peer Group's Scope 3 2026 Tools Review, only 15% of 144 practitioners described their Scope 3 programs as advanced, predominantly using granular, supplier-specific data, with most (66%) still working from a mix of average and supplier-specific data.
From measuring emissions to showing how they will fall
The revised climate standard also asks companies to explain how reductions will happen. A transition plan has to set out the company's reduction targets alongside the decarbonization levers it expects to use, and a company without one must say whether and when it expects to adopt one. Under the Omnibus, companies no longer have to adopt a plan under the Corporate Sustainability Due Diligence Directive (CS3D), but this disclosure under the CSRD remains. Companies also report their main climate actions against the decarbonization lever each one relates to, with the reductions achieved so far and those still expected. Any reduction targets have to be absolute, covering Scopes 1, 2, and 3 separately or combined, with no credits or removals counted toward them.
For most manufacturers and consumer brands, much of the footprint sits in Scope 3, so many of the levers a credible plan relies on sit inside supplier facilities. Industrial heat is one of the largest of those levers, and the International Energy Agency (IEA) found that renewables met just 12% of global industrial heat consumption in 2024. Across Secaro's own supplier data, natural gas is the largest single source of facility-level direct emissions in every sector we track.
Reporting progress against those levers depends on change happening at supplier facilities, and information about suppliers' own reduction plans sits outside what the value chain cap lets a company require. Initiatives like the Clean Heat Program, developed by Secaro with ERM, support suppliers in understanding how heat is used across their facilities and in building investment-ready plans to change it.
Where the pressure on supplier data comes from now
Companies outside the CSRD's scope can still be caught indirectly through the value chains of in-scope customers, including those based outside Europe, and the CSRD now sits alongside other frameworks that ask for the same underlying supplier data. CBAM already rewards verified, facility-level emissions figures, and the Science Based Targets initiative (SBTi) Corporate Net-Zero Standard V2.0 asks companies to prioritize suppliers of emission-intensive materials.
The Omnibus narrowed who reports and how much, but the expectations around Scope 3 data quality and reduction plans are still in place. Companies that use the period before 2027 to agree what they need from their most significant suppliers, and to build relationships that go beyond the minimum the cap allows, will be better placed when the first reports under the revised standards arrive in 2028.
