Your enterprise customers must report Scope 3. The next question is coming to you.
CSRD requires large companies to demonstrate how they manage environmental impact across their entire supply chain. That means they need to know you have processes, ownership and follow-up in place.
CSRD phase-in after Stop-the-Clock
The EU's Stop-the-Clock Directive (2025/794) postpones Waves 2 and 3. Omnibus I may change the thresholds further. Here is the current status.
Wave 1: Reporting since FY 2024
Large listed companies with over 500 employees (previously under NFRD). These companies are already reporting and placing demands on their supply chain.
Wave 2: Postponed to FY 2027
Other large companies. Originally FY 2025, now FY 2027 through Stop-the-Clock. Omnibus I may raise the threshold to over 1,000 employees.
Wave 3: Postponed to FY 2028
Listed SMEs. Originally FY 2026, now FY 2028. SMEs wanting to report voluntarily can use the VSME standard (published July 2025 by the European Commission).
The European Commission has also published simplified ESRS standards with significantly fewer mandatory datapoints. National transposition timelines vary by member state, with several governments waiting for the Omnibus I outcome.
How the requirements reach you
CSRD places requirements on large enterprises. But Scope 3 means they need data from their entire supply chain - and that includes you.
Covered by CSRD (Wave 1 since 2024)
The largest listed companies are already reporting under ESRS. Waves 2 and 3 have been postponed to 2027/2028 by Stop-the-Clock, but the demand for supplier data is not waiting.
Scope 3 requires supplier data
The enterprise cannot report without data from their suppliers. They send questionnaires, set requirements, and request documentation.
You need to show you have processes
Documented environmental aspects, goals with assigned owners, management review and improvement actions. A working management system, not a sustainability policy PDF.
The governance that makes CSRD reporting possible
CSRD requires more than datapoints. It requires processes, responsibility and improvement. AmpliFlow with ISO 14001 gives your environmental work that structure, not as a side project but as part of how you already work.
Processes with clear ownership
Define who is responsible for collecting environmental data, reviewing it and acting on the results. CSRD requires more than numbers. You need to show how those numbers are produced.
Management review
Structured management reviews where environmental data, non-conformities and improvements are assessed. CSRD's double materiality assessment requires active decisions from leadership, not just signatures.
Goals, tracking and improvement
Set environmental goals, assign owners and follow up with measurable KPIs. Your management system shows that you do more than measure. You improve.
What you need to have in place
Whether you are preparing for your own requirements or your customers' - this is what is needed.
Environmental aspects register
Document which environmental aspects your operations have and who is responsible for each area. The foundation for all environmental reporting.
Stakeholder analysis
Map who places requirements on you and who is affected by your operations. Customers, regulators, society.
Environmental goals with owners
Concrete, measurable goals linked to your significant environmental aspects. Deadlines, assigned owners and scheduled follow-up.
Documented processes
Processes for waste management, energy efficiency, chemical handling. Documented, accessible and with clear process owners.
Supplier management
Structured supplier management with assessment criteria. Your customer needs Scope 3 data, and you need a process for collecting it from your suppliers.
Audit and improvement
Internal audits and management review with traceability. You show not only where you stand, but that you systematically improve.
Questions about CSRD and the supply chain
What is CSRD?
CSRD (Corporate Sustainability Reporting Directive) is the EU directive on sustainability reporting. It requires large companies to report on their environmental and social impact according to the ESRS standards. Wave 1 (the largest listed companies) has been reporting since FY 2024. Waves 2 and 3 have been postponed by the Stop-the-Clock Directive (EU 2025/794) to FY 2027 and FY 2028 respectively. The EU's Omnibus I proposal may also raise the threshold to companies with over 1,000 employees, but it is still pending adoption.
Are we directly covered by CSRD?
Most small and medium-sized companies are not directly covered by CSRD. But your enterprise customers who are covered need environmental data from their supply chain for Scope 3 reporting. This is not a legal obligation for you, but a commercial requirement: without your data, their report lacks completeness. SMEs wanting to report voluntarily can use the VSME (Voluntary SME Standard), published by the European Commission in July 2025.
What is Scope 3 and why does it concern us?
Scope 3 covers indirect emissions in a company's value chain, meaning what happens at suppliers, transport providers and customers. When an enterprise reports Scope 3, they need data from every link in the chain. That likely includes you.
What do Stop-the-Clock and Omnibus I mean?
The Stop-the-Clock Directive (EU 2025/794) postpones CSRD reporting for Wave 2 (large companies) and Wave 3 (listed SMEs) by two years, to FY 2027 and FY 2028 respectively. Wave 1 companies are not affected. Omnibus I is a separate proposal that may raise the size threshold so that only companies with over 1,000 employees are covered. The European Commission has also published simplified ESRS with significantly fewer mandatory datapoints.
How does a management system help with CSRD requirements?
CSRD requires more than numbers. It requires you to demonstrate that you have processes for collecting data, that someone is responsible, that management reviews results and that you improve. ISO 14001 in AmpliFlow provides exactly that structure: environmental aspects, goals, management review and non-conformity handling. The data can live in AmpliFlow or in other systems. The management system ensures the process exists and works.
Is AmpliFlow enough for CSRD reporting?
AmpliFlow is not a CSRD reporting tool. It is the management system that makes CSRD reporting possible: you define processes, assign responsibility, conduct management reviews and drive improvements. The actual report file is produced in your reporting tool. AmpliFlow ensures the underlying data is structured, reviewed and traceable.
Be ready when the question comes
Book a demo and we will show you how AmpliFlow gives your environmental work the structure CSRD requires: processes, ownership, follow-up and improvement.