# CSRD Double Materiality: What an MSME Supplier to a CSRD Company Must Provide

Canonical: https://senseible.earth/climate-intelligence/csrd-double-materiality-assessment-msme-supplier

Published 2026-05-06.

As an MSME supplier you are almost certainly not directly in scope of CSRD, which applies to large companies (and was narrowed further by the EU's Omnibus simplification). You are still in its reach as a supplier. Here is what your EU customer will ask for.

## Double materiality in plain English

CSRD requires the EU buyer to disclose two things for every material topic:

1. Impact materiality: how their business affects the environment and society
2. Financial materiality: how environmental and social factors affect their business

You sit on both sides. Your emissions are part of their Scope 3 (impact). Your climate-related risks (drought, flood, energy disruption) feed their financial risk disclosure.

## The supplier questionnaire to expect

| Section | Typical questions | Where to source data |
| --- | --- | --- |
| Governance | Board oversight of climate? | Your sustainability charter |
| Strategy | Net zero target year? | Your roadmap |
| Risk | Top 3 physical climate risks? | Geographic exposure analysis |
| Metrics | Scope 1, 2, 3 in tCO2e? | [Senseible](https://senseible.earth/) |
| Targets | SBTi validation? | SBTi portal or N/A |
| Transition plan | Capex committed to abatement? | Capex register |

## What an honest small supplier should answer

Pretending to have a board climate committee when you have a 12-person company damages credibility. Say: "Founder-led oversight. Quarterly review of emissions and abatement spend." That is a credible answer.

## The minimum data pack

- Scope 1 + 2 in tCO2e for last full year
- Scope 3 categories 1 (purchased goods) and 4 (upstream transport) at minimum
- Emission intensity per unit of product sold to that buyer
- One-page transition plan with year, action, expected reduction
- Disclosure of any verifications or third-party reviews

## Timing

Wave 1 companies already report under CSRD, so questionnaires can arrive at any time. The EU's 2025 "stop-the-clock" directive postponed reporting for wave 2 (large companies not yet reporting) by two years, to financial year 2027, and the Omnibus simplification removed listed SMEs from scope. Be ready now rather than waiting for a deadline.

## Related guides

- [Can we reroute supply chains to reduce CBAM exposure legally?](https://senseible.earth/climate-intelligence/reroute-supply-chains-reduce-cbam-exposure)
- [CBAM for Indian Exporters: What Changed on 1 January 2026](https://senseible.earth/climate-intelligence/cbam-compliance-indian-exporters)
- [BRSR Reporting Requirements in India: Who Reports, BRSR Core and Value-Chain Rules](https://senseible.earth/climate-intelligence/brsr-reporting-requirements-india)