CSRD chain requests: what if I don't have to report myself?
Adopted 2026-06-14 · ≈ 1 min read · 
edited by Dirk Baaijen
After the 2026 Omnibus, almost all transport and logistics firms fall outside the direct CSRD duty, yet large clients, banks and insurers still request ESG and CO2 data through the supply chain.
Short answer: Even without your own reporting duty, CSRD will almost certainly reach you. Large clients, banks and insurers that do fall under the directive need your ESG and CO2 data to map their own chain.
Why you probably fall outside the direct duty
The CSRD is set out in Directive (EU) 2022/2464. The Omnibus, published in February 2026, narrowed its scope by roughly 90%. Only EU companies with more than 5,000 employees and more than 1.5 billion euro in turnover still fall under it directly. For non-EU companies a threshold of more than 1.5 billion euro in EU turnover applies. The 'stop the clock' measure also postponed the applicable deadlines by two years.
As a result, the large majority of the transport and logistics sector remains outside the direct reporting duty. A dedicated sustainability report under the CSRD standards is therefore not mandatory for most carriers, forwarders and warehousing parties.
Why the chain still reaches you
The CSRD requires reporting companies to include their value chain. A large client that does fall under the directive must account for the emissions and ESG performance of its transport and logistics. That translates into concrete requests: CO2 figures per shipment, fuel consumption, fleet data and policy documentation.
Banks and insurers ask these questions too, because they must account for their own portfolio. The request therefore comes not from the legislator but through your contractual relationships. Those who cannot deliver risk losing contracts or facing less favourable terms.
What this means in practice
Treat chain requests as a commercial precondition, not a legal obligation. Make sure you can supply reliable CO2 and ESG data in the format your customers use. An early, orderly approach makes you a more attractive chain partner and avoids ad-hoc work under time pressure.
Read the main file: CSRD sustainability reporting in transport. Or take the Transport & Logistics scan.
Sources
- https://eur-lex.europa.eu/eli/dir/2022/2464/oj
Directive (EU) 2022/2464 (CSRD); sharply narrowed by the 2026 Omnibus.
Read next
Does my transport company still report under CSRD after the Omnibus?
Probably not directly. The Omnibus narrowed the CSRD scope by about 90%: only EU companies with >5,000 employees and >EUR 1.5bn turnover are still in scope. Even so, large clients, banks and insurers often still request ESG data through the supply chain.
CSRD after the Omnibus: who in transport still has to report?
The Omnibus (published February 2026) cuts the CSRD scope by around 90%: only EU companies with more than 5,000 employees and more than €1.5bn turnover remain in scope. 'Stop the clock' delayed deadlines by two years. What that means for transport and logistics.
NIS2: what exactly does the 24/72-hour reporting duty involve?
For a significant incident, NIS2 sets tight deadlines: an early warning within 24 hours, a formal notification within 72 hours and a final report within a month — to the national authority/CSIRT. What counts as significant, and how to set yourself up for it.