CSRD reporting kicks off in 2026 for large EU companies, triggering immediate ESG data demands on their suppliers via value chain disclosures. SMEs need to prepare now to avoid rushed requests, inconsistent answers, and lost contracts. This guide breaks down the timeline, the key data asks, and a quick-start checklist you can run in Complezy — including attaching evidence upfront so your responses are audit-ready.
CSRD timeline for suppliers
Large companies (typically 500+ employees and €150M+ revenue) file their first CSRD reports by mid-2026 for FY2025 data. That reporting requires upstream supplier inputs on impacts like emissions and labor practices.
Phase 2 (2027 filings for FY2026) expands the population of in-scope firms. As more buyers formalize their processes, suppliers should expect questionnaire volume to increase and become more standardized — and more auditable.
Expect data requests starting in Q1 2026 with 2–4 week deadlines tied to customers’ audit and reporting cycles. Non‑EU suppliers can face the same requirements through contract clauses when serving EU buyers.
Value chain data demands
Customers will request supplier data aligned to ESRS topics such as E1 (climate, including Scope 3 inputs), S1 (workers), and G1 (governance). Upstream suppliers often get hit hardest because buyers need primary data and evidence to support assurance.
Common asks include energy use, waste, incidents, diversity metrics, and policy controls — plus evidence such as invoices, certifications, and audit reports.
Requests will become annual and increasingly auditable: raw numbers plus narratives on risks and mitigations. Inconsistent data typically triggers follow-ups or audits, while strong evidence-backed responses build trust.
Quick-start checklist
Follow this 5-point plan in Complezy to handle 2026 requests without chaos.
- Gather core data now: input Scope 1–2 emissions (from Finance bills), workforce stats (HR), and policies (Ops) into Complezy’s workspace.
- Attach evidence upfront: link invoices, ISO certifications, and audit reports directly to the relevant metrics.
- Test auto-fill: upload a sample CSRD supplier template; Complezy maps questions to your data, proposes answers, and flags gaps.
- Set tracking: manage requests, deadlines, and roles in one dashboard; enable reminders for quarterly updates.
- Export ready: generate branded PDFs/spreadsheets with consistent numbers and embedded evidence so customers can use your inputs confidently.
We have a free tool to check if your business is within scope of CSRD — click the button below.
Check your CSRD scopeKey takeaway
2026 marks the first CSRD filings, with supplier ESG requests ramping from Q1 for FY2025 value-chain data across climate, workers, and governance. Focus on 10–15 ESRS-aligned metrics with evidence attached, then test your setup end-to-end with a template questionnaire. Proactive suppliers respond in hours, win trust, and stay competitive — and Complezy helps you do it without adding headcount. Next step: use our CSRD Checker to confirm whether you or your customers are in scope and what to prepare /tools/csrd-checker