3. Mar 2025
When most people hear about the Corporate Sustainability Reporting Directive (CSRD), they assume it only applies to the biggest corporations. Since the EU’s Omnibus I simplification entered into force on 18 March 2026, that is largely true for the reporting obligation itself – but the effects still reach far beyond those companies:
Source: Directive (EU) 2026/470 (Omnibus I). EU Member States must transpose the changes into national law by 19 March 2027.
But here’s the catch: companies outside the scope can still be asked for data. Large companies that report must cover their value chain – including the Scope 3 emissions of subcontractors, logistics partners and suppliers.
Omnibus I sets a limit: partners with up to 1,000 employees cannot be required to provide more than the EU’s voluntary SME standard (VSME) covers, and they must be told when a request goes beyond it. But the VSME’s basic module already includes total energy consumption – with fuels split into renewable and non-renewable – and Scope 1 and 2 greenhouse gas emissions (Commission Recommendation (EU) 2025/1710). In other words: even if you’re not required to report, your customers can still ask for your fuel use and emissions.
For both large corporations and smaller hauliers, logistics firms, or suppliers, this makes understanding double materiality and value chain emissions essential — today, not tomorrow.
For the full framework connecting Scope 1, 2, and 3 emissions to CSRD reporting, SBTi targets, and Proof of Sustainability documentation, see our complete guide to emissions reporting.
Double materiality requires companies to assess and report on two dimensions of sustainability performance:
This means reporting is no longer limited to direct emissions and operational performance — it extends to the entire value chain, including the environmental and financial consequences of third-party suppliers and subcontractors.
Large corporations, haulers and logistics providers are in a unique position because their environmental impact is not only driven by their own fleet and operations (Scope 1 and Scope 2) but also by the broader transport ecosystem — including the subcontractors and transport partners they work with (Scope 3).
Learn more about Scope 1, 2 and 3 here.
Scope 3 emissions represent the most complex and significant challenge under the CSRD for companies because they include emissions from subcontractors and third-party partners.
Scope 3 emissions include:
• Emissions from transport subcontractors you hire to carry goods.
• Fuel consumption from third-party transport providers.
• Emissions from upstream suppliers (e.g., fuel producers).
• Lifecycle emissions of the vehicles in your fleet.
• End-of-life emissions from scrapping vehicles or equipment.
• Business travel and employee commuting.
Example:
If you subcontract a third-party logistics company to deliver goods, the emissions from their trucks will count as your Scope 3 emissions under the CSRD.
If your subcontractors use fossil fuels or operate inefficient fleets, their emissions are reflected in your overall sustainability report.
Tracking Scope 3 emissions requires collaboration across the supply chain. You need accurate data from subcontractors on fuel consumption, emissions factors, and transport volumes.
Example:
If you hire a subcontractor for last-mile delivery, you’ll need to gather data on the type of fuel they use, distance travelled, and load weight — and then integrate that into your sustainability report.
Even if your company isn’t directly required to publish a CSRD report yet, you may already feel the effects because:
In other words: smaller companies feel CSRD through customer contracts – within the limits Omnibus I now sets.
Scope 3 reporting may feel overwhelming — especially for transport and logistics companies where subcontractors play such a big role. But with the right approach, tools, and partnerships, it’s possible to turn this complex task into a structured process that delivers both compliance and competitive advantage.
Use Renewable Fuels Like HVO100
Switching to renewable fuels like HVO100 can significantly reduce Scope 1 and Scope 3 emissions.
• HVO100 reduces lifecycle emissions by up to 86% compared to fossil diesel*.
• Subcontractors using HVO100 will contribute lower emissions to your overall Scope 3 profile.
* Based on 2025 verified delivery data. Actual reduction per delivery ranges from 57% to 121% depending on feedstock composition and certified batch. Calculated per the RED III well-to-wheel life-cycle methodology using ISCC-certified mass balance allocation. Proof of Sustainability (PoS) documentation available on request.
Engage with Subcontractors Early
• Establish emissions reporting standards for all subcontractors.
• Include emissions reporting requirements in subcontractor contracts.
• Encourage subcontractors to switch to renewable fuels and vehicles with documented lower emissions.
Invest in Emissions Tracking Tools
• Use platforms like Biofuel Express Insight to track and measure emissions from subcontractors and direct operations.
• Provide subcontractors with guidance on how to collect and report accurate emissions data.
Partner with Certified Suppliers
• Choose subcontractors and fuel providers that can document their emissions data.
• Partner with suppliers certified under recognised sustainability standards (e.g., ISCC).
Start Early and Build a Framework
• Establish an internal emissions tracking framework.
• Start with pilot projects to refine data collection and reporting methods.
• Develop an emissions reduction roadmap aligned with CSRD requirements.
If you’re ready to explore how to reduce emissions and simplify compliance, get in touch with us. We help you turn complex regulation into measurable impact.
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