Key Change in CSRD Scope 3 Reporting:
- CSRD would apply only to companies with more than 1,000 employees and > €450m net turnover. The deal also removes listed SMEs from scope, exempts financial holding undertakings, and introduces a transition exemption for “wave-one” companies that started reporting for FY2024 but would fall out of scope for 2025/2026 under the new thresholds. This is still provisional and requires formal endorsement by Council and Parliament. > More Information
- Delay backdrop (“stop-the-clock”): Earlier measures postponed first-time reporting for wave-two and wave-three companies by two years, giving additional preparation time.
- Scope-3 relief (“ESRS quick fix”): For first-wave reporters, the Commission’s 2025 ESRS “quick fix” extends certain phase-in reliefs for 2025/2026, while some reliefs (including around Scope-3) remain tied to the <750-employee threshold.
Business impact: What Manufacturers and Suppliers Should Do Now
- Reassess CSRD applicability under the new 1,000 staff + €450m thresholds - many previously in-scope companies may drop out.
- If you remain in scope, Scope-3 is still a cornerstone of credible climate reporting because it relies on value-chain transparency and robust data governance. (Legal scope changes are as above; broader market expectations remain.)
- Design proportional supplier requests: the EU explicitly aims to reduce “trickle-down” burdens, so value-chain data programs should be standardized and SME-friendly.
Even where companies fall outside formal CSRD reporting requirements, Scope-3 emissions remain strategically relevant. Value-chain emissions data continues to be requested by CSRD-reporting customers, financial institutions and rating agencies, and is increasingly needed to support decarbonisation targets, customer requirements and credible sustainability strategies. As a result, Scope-3 transparency is evolving from a pure compliance topic into a market and value-chain expectation.
IPOINT and Scope 3 Reporting
CSRD Scope-3 reporting succeeds when carbon accounting is embedded in the company-wide Corporate Carbon Footprint and connected to structured supplier and emissions data. IPOINT helps translate Scope-3 complexity into actionable workflows - from data collection to analysis and reporting readiness.
Not sure how to approach Scope-3 requirements in a strategic and efficient way?
