What to Do When Your Supplier Can’t Provide CSRD Data

Introduction

For many SMEs implementing the Corporate Sustainability Reporting Directive (CSRD), supplier data collection is the hardest part. Even when you send a clear and simple questionnaire, some suppliers will reply: “We don’t have that data.”

This is not a failure — it’s part of the early learning curve for sustainability reporting. The key is knowing how to respond effectively and transparently. Under CSRD, it’s acceptable to use estimates, industry averages, or proxy data when supplier information isn’t available, as long as you disclose your assumptions.

This guide explains how to fill those data gaps, how to encourage future improvement, and how to maintain credibility in your Scope 3 reporting.

Start with the supplier questionnaire template →

Why Some Suppliers Can’t Provide Data

Suppliers may struggle for several reasons:

• They’re not in scope for CSRD and don’t yet collect sustainability metrics.
• They lack tools or staff to measure energy use, emissions, or workforce data.
• They’re afraid of sharing “wrong” numbers or commercially sensitive information.
• They haven’t yet heard of the VSME Standard, which provides an easy framework for SMEs.

Understanding these barriers helps you respond constructively rather than punitively.

Learn more about the VSME Standard →

Step-by-Step: What to Do When Data Is Missing

1. Confirm What’s Really Missing

First, identify which indicators you didn’t receive. Are these essential for your Scope 3 emissions or social disclosures? You may not need every single data point if it’s immaterial. Focus on:

• Energy and fuel use (for GHG emissions)
• Waste and recycling data
• Workforce headcount or safety figures

Sometimes suppliers have partial information (like electricity bills) but don’t recognise it as “CSRD data.” Help them see how this data fits into the bigger picture.

See how to request CSRD data effectively →

2. Use Estimations and Proxies

If no direct data is available, you can use reasonable estimates based on:

• Spend-based methods: Calculate emissions per euro spent using emission factors from databases like Exiobase or EEIO.
• Average intensity data: Use sector averages from national statistics or lifecycle databases.
• Historical or peer data: Apply figures from similar suppliers or prior years, adjusted for scale.

Be sure to document your assumptions — transparency is more important than precision in early reporting years.

3. Apply the VSME Approach

Encourage suppliers to adopt the VSME Basic Module, which includes standardised disclosures for energy, emissions, workforce, and governance. Even small businesses can complete the B1–B11 questions without specialist software.

If suppliers start using this format, you’ll receive structured, comparable data next year — saving time for both sides.

Learn how to use the VSME Basic Module →

4. Mark Data Confidence Levels

Include a confidence rating (e.g. high, medium, low) in your internal data file. This practice aligns with good data governance and helps explain variation in year-to-year results. Example:

5. Plan for Improvement

CSRD reporting is iterative. Use this first cycle to identify weak spots and build engagement for the next. You can:

• Provide suppliers with a simple VSME-based template next year
• Offer a short sustainability workshop or online guide
• Align contract clauses with minimum data expectations

The goal isn’t punishment — it’s gradual capacity building across your value chain.

Practical Example

Scenario: You buy packaging from a small manufacturer in Italy. They don’t track energy use or emissions.

Solution:

• Estimate emissions using average energy intensity for packaging manufacturers (available in national databases).
• Note the estimation method in your report: “Supplier data unavailable; emissions estimated based on industry average.”
• Offer them a VSME template for next year’s cycle.

This approach meets CSRD expectations for reasonable effort and transparency.

Frequently Asked Questions

Can I still comply with CSRD if supplier data is missing?

Yes. CSRD allows estimates and proxy data when suppliers can’t provide figures, provided you document the method and explain limitations. You should also describe how you plan to improve future data quality.

Learn how Scope 3 affects SMEs →

Should I exclude non-responsive suppliers from reporting?

No. Excluding them would understate your impacts. Instead, estimate their contribution using reasonable proxies and clearly label it as such in your disclosure.

How do I motivate suppliers to start reporting?

Share how sustainability data can help them win contracts and attract financing. Point them to the VSME Standard, which gives small businesses a simple entry point to structured sustainability reporting.

Share our guide on requesting CSRD data from suppliers →

What if suppliers refuse due to confidentiality?

Explain that you don’t need sensitive financials — only operational data like energy use or workforce numbers. Offer anonymisation or aggregated reporting to protect their privacy.

Key Terms

• Scope 3 Emissions: Indirect emissions from a company’s value chain (e.g. purchased goods, logistics).
• Proxy Data: Substitute figures from reliable averages or databases when direct data is missing.
• VSME Standard: Voluntary EU framework to help SMEs provide simplified sustainability information.
• Data Confidence Level: A qualitative indicator of how reliable each dataset is.
• Due Diligence: Ongoing process to identify, prevent, and mitigate sustainability risks in supplier relationships.

Conclusion

Missing supplier data doesn’t have to derail your CSRD reporting. What matters most is making a reasonable effort, using transparent estimation methods, and building supplier capacity for next year. By applying the VSME framework and documenting your approach, you can maintain credibility, meet reporting standards, and foster genuine sustainability collaboration across your value chain.

If your supplier is struggling to provide data, you can help them by sharing a customised checklist. Use our checklist generator to create a data collection checklist that you can share with your supplier:

This tool will help you create a structured checklist that your supplier can use to understand what data they need to collect, making it easier for them to respond to your requests in the future.