ESRS E1: When your climate roadmap depends on Scope 3
E1-1 requires more than just a promise of carbon neutrality: it demands a roadmap with dated milestones and allocated resources. However, Scope 3 often becomes a roadblock long before the roadmap itself is even addressed, as the necessary data simply does not yet exist for a large portion of suppliers.
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Context note:
This article is based on ESRS E1 as it currently stands in early August 2026. As I explained in my article "The vertigo of CSRD monitoring", the revised ESRS adopted on July 3, 2026, could modify this standard; they remain subject to review by the Council and the European Parliament. I will update this article if the final text changes the situation.
ESRS E1 is the climate standard for the CSRD, structured into nine disclosure requirements, ranging from strategy and transition plans to the anticipated financial effects of physical and transition risks.
E1-1 requires the publication of a transition plan compatible with a 1.5°C trajectory and the European goal of climate neutrality by 2050, including short-, medium-, and long-term milestones, the associated resources, and identified governance.
The text also requires a documented roadmap.
E1-6, the most data-intensive disclosure in the standard, requires the separate publication of Scope 1, Scope 2, and Scope 3 emissions across all relevant categories of the value chain.
Scope 3 benefits from a relief measure for companies with fewer than 750 employees, which may omit it during their first year of reporting, but this does not exempt them from starting to build the collection infrastructure now.
The second-tier wall
According to the tenth edition of the EcoVadis Sustainability Ratings Index (July 2026), based on nearly 200,000 assessments conducted between 2021 and 2025, only 19% of suppliers publish their upstream Scope 3 emissions, and 30% report no carbon data at all.
These figures refer to suppliers already engaged in an assessment process, meaning they are among the most advanced in the market; across supply chains as a whole, the reality is likely much worse.
The problem is rooted in documentation, and it goes beyond just carbon. Across all themes assessed by EcoVadis, a majority of companies have practices in place that they fail to document:
- 97% have at least some measures in place regarding human and social rights, but only 75% report them.
- In ethics, 80% have measures in place, while 38% document them.
- Regarding sustainable procurement, historically the weakest theme in the framework, these rates drop to 66% and 36%.
This barrier also affects the tools intended to overcome it. 68% of procurement professionals have already deployed artificial intelligence in their sustainability programs, and 85% of the most advanced buyers are already collecting product-level carbon footprints across their supply chains. However, these systems can only process data that, for a large portion of suppliers, simply does not exist yet.
We have industrialized the analysis before the data actually exists.
The VS, a common framework, not a guarantee of data
Faced with this hurdle, the Voluntary Standard (VS)—formerly known as VSME and formally adopted by the European Commission on July 3, 2026—provides a partial solution.
It provides unlisted companies with up to 1,000 employees and €450 million in revenue—those falling outside the scope of the CSRD following the threshold increases under the Omnibus directive—with a common format for responding to client requests, rather than having to fill out a different questionnaire for every customer. In the same act, the Commission confirmed a "value-chain cap": companies subject to the CSRD cannot request more data from their value-chain partners than what is covered by the VS.
However, the VS remains limited regarding Scope 3. Its Basic Module, most commonly used by smaller entities, covers Scope 1 and Scope 2, and only requires Scope 3 data when relevant and feasible, without detailed methodology or granular supplier data. The Comprehensive Module goes further, including reduction targets and transition plans, but it is currently not widely adopted as a first step.
The VS should therefore reduce part of the documentation burden at the source, specifically the issue caused by the proliferation of non-harmonized questionnaires. Upstream Scope 3 remains optional in its basic module, which is precisely where the second-tier hurdle lies.
What is needed to properly document E1
Publishing a credible trajectory requires being able to link every emission category to its source. But when that source does not yet exist at the supplier level, collection infrastructure alone is not enough to solve the problem. As an ESG analyst at Ascend, I encounter this documentation wall in my own work: qualifying a Scope 3 emission for a client often means realizing that the data does not yet exist at their supplier's end, rather than simply needing to go out and retrieve it.
Companies that have been part of the EcoVadis network for over ten years score an average of 12 points higher than those being evaluated for the first time, with an average of 63.2 compared to 51.5.
Long-term engagement, rather than one-off audits, is what drives supplier improvement.
Properly documenting E1 requires as much focus on supporting suppliers in measuring their impact as it does on the collection infrastructure used to request proof.