The Corporate Sustainability Reporting Directive (CSRD) is the European directive (EU 2022/2464) that drastically expands the scope of corporate non-financial sustainability reporting. Before, you had to report if you were a large listed company; now — with progressive scopes through 2028 — the obligation extends to nearly all large and medium-large companies operating in Europe, with annual public reports, mandatory audit, double materiality (impact on the company and impact of the company on the external world) and detailed ESRS standards. For European forwarders the practical consequence is not an immediate direct obligation — many fall below threshold — but a domino effect of requests from large consignees, who need data and evidence to close their Scope 3 and supply-chain sections.
Disclaimer — This article is informational. For your specific CSRD scope, first-application timing and applicable ESRS standards, refer to the regulations published by the European Union, EFRAG and national transposition authorities. Your legal counsel and statutory auditor are the right interlocutors.
Who is directly involved
CSRD applies in progressive scopes:
- 2025 (reporting 2026) — large public-interest companies already under NFRD
- 2026 (reporting 2027) — all large companies (>250 employees, turnover >€50M, assets >€25M — meeting 2 of 3 criteria)
- 2027 (reporting 2028) — listed SMEs
- 2029 (reporting 2030) — non-EU companies with significant EU presence
The average mid-size forwarder is often below the direct obligation threshold. The large consignee — manufacturer, retailer, large-scale chain, multinational chemical/pharma/food — is typically in the 2026 or 2027 scope.
Why forwarders get involved anyway
The CSRD-subject consignee must report supply-chain emissions (Scope 3 per the GHG Protocol). Categories 4 (upstream transportation) and 9 (downstream transportation) directly capture the transport of goods the consignee buys or sells. To close Scope 3, data the consignee never asked for before is needed:
- Tonne-kilometres per lane or equivalents
- Vehicle type and associated emission factor (Euro 5, Euro 6, HVO, LNG, electric)
- Effective load factor per lane
- Empty backhauls counted in emissions
- Audit evidence documents (digital PoDs, tachograph logs, invoices)
The consignee passes these requests to the forwarder as tender attachments or contractual clauses. The forwarder lacking structured data delivers it patchwork, losing tender score and reliability.
Operational data missing in most forwarders today
Three typical gaps in the data stack of an average European forwarder.
Effective load factor. How full was the trailer on that lane? Without an operational system that records it (volumes, weight, packing), it gets estimated post-hoc from the planned shipment, which is far different from actual load.
Specific carrier-vehicle assigned. Forwarders often know which carrier got the assignment, not which specific plate. Emission factor requires Euro class and engine size: without VIN it's an estimate.
Empty backhauls associated. If carrier A returned empty from Munich to Verona after delivering for consignee B, does that empty weigh on B's emissions? GHG Protocol methodologies distinguish cases: the data must exist.
Double materiality — the concept to understand
CSRD requires reporting under two lenses, simultaneously:
Inside-out (impact materiality). The company reports how it affects the outside world: direct, indirect, supply-chain, social, governance impacts.
Outside-in (financial materiality). The company reports how sustainability topics affect its own financial results: physical risk (climate events on warehouses), transition risk (regulation cutting revenues), reputation risk.
For a forwarder engaged as supplier, consignee requests start from inside-out: the consignee must declare its Scope 3 emissions and asks you for the numbers. But the consignee under pressure from PE funds and banks with EU Taxonomy requirements also needs evidence to demonstrate effective reduction over time. Multi-year time series matter.
What to do today (even if not in direct scope)
Three actions a mid-size forwarder can activate now to be "CSRD-ready" as supplier of large consignees.
- Structure carrier-vehicle data in shipments — assignment must record specific plate, not just generic carrier. Plate enables correct emission factor.
- Digitize PoD with evidence — a PoD with GPS at upload and integrity hash is also audit evidence for the consignee. The same file serves two worlds.
- Track empty backhauls and load factor — every closed shipment records actual empty km and actual load. Without these data the CSRD-subject consignee looks for another forwarder who has them.
FAQ
Does CSRD apply to my small Italian forwarder?
Probably not directly in the next 2-3 years — initial scopes cover large companies and listed SMEs. Indirectly yes, through requests from large consignees in scope asking Scope 3 data from their transport suppliers. For specific scope, refer to European regulation and national transposition; your legal counsel is the right interlocutor.
What are the GHG Protocol categories for transport?
Main ones are Scope 3 category 4 (Upstream transportation and distribution — transport of goods the consignee buys) and Scope 3 category 9 (Downstream transportation and distribution — transport of goods the consignee sells). Calculation methods are based on tonne-kilometres, vehicle emission factor and load factor.
What is CSRD's double materiality?
CSRD requires reporting under two lenses: impact materiality (the company's impact on the outside world — emissions, social, governance) and financial materiality (the outside world's impact on the company's financial results — physical, transition, reputation risks). Companies report both simultaneously.
Are digital PoDs useful for CSRD reporting?
Yes as audit evidence. A digital PoD with GPS at upload time and integrity hash documents that transport actually occurred that way, that day, with that signature. It's documentation the consignee's CSRD auditor can request as a sample to validate declared Scope 3 data.
How long does it take to be "CSRD-ready" as a supplier?
Depends on data starting state. A forwarder managing shipments today with email + Excel typically needs 6-12 months to structure carrier-vehicle data, digitize PoDs and track empty backhauls. A forwarder already on a structured TMS platform can be CSRD-ready in 2-4 months with the right data and reporting layer.
Want to understand how to structure data to be CSRD-ready supplier of your large consignees without burdening operations? Request a private demo on the forwarders page or read the article on exclusive carrier networks for the tracked sourcing model.