Most mid-size forwarders are not CSRD-obligated. Not LkSG-obligated either. That part is true. The supply chain evidence questionnaire still lands in their inbox. Since the Omnibus reform, CSRD starts at 1,000 employees. And over 450 million euros in revenue. Germany's LkSG only ever applied above 1,000 domestic employees. Yet plenty of forwarders have a form waiting right now. From their biggest customer. Asking about subcontractors. About CO2 per shipment. About human rights risk in the chain. The comfort of not being named in the law is the wrong comfort.
My position: the obligation does not travel through the statute. It travels through the contract. The large customer is the one who must report. It needs its suppliers' evidence. To close its own filing. The forwarder supplies it. Whether the law names it or not.
The Omnibus Directive (EU) 2026/470 hit the Official Journal on 26 February 2026. National transposition is due by 19 March 2027. It raises the CSRD threshold. To 1,000 employees. And over 450 million euros in net turnover. The number of directly obligated companies drops. By roughly 90 percent against the first draft. Smaller suppliers get a shield of their own. The Value Chain Cap. Companies under 1,000 employees count as "protected undertakings". They may decline requests. When those go beyond the voluntary VSME standard. VSME itself is expected to be final around June 2026, per current reporting.
The CSDDD, the EU's due diligence directive, moved on its own clock. The Stop-the-clock Directive (EU) 2025/794, dated 16 April 2025, reset the start date. For the largest companies, to 26 July 2028. For the next tier, above 1,000 employees and 450 million euros in turnover, to 26 July 2029.
Germany's LkSG sits in limbo. The federal cabinet approved an amendment bill on 3 September 2025. It strikes the reporting duty under Section 10(2). Retroactive to 1 January 2023. BAFA got ahead of the bill on its own. Its page states, as of 7 November 2025: report review under Sections 12 and 13 LkSG has stopped entirely. The digital reporting form is switched off. The Bundestag held its first reading on 16 January 2026. As of this article's research, the bill had not passed. The underlying due diligence duties stay in force. Only severe violations are still pursued. The plan is to replace the LkSG later with a CSDDD implementation law.
Three moving deadlines, then. One constant stays: a customer above 1,000 employees remains obligated. Whichever date ends up governing it.
The obligated customer needs scope 3 emissions. Those sit in its supply chain. Not in its own fleet. It needs evidence on human rights and environmental risk at its subcontractors. That evidence sits with the forwarder. And with the forwarder's own subcontractors. So the customer sends a questionnaire. To every supplier. Including the one no law ever names.
The Value Chain Cap allows declining questions beyond VSME. Legally, that holds. In practice, the next framework contract decides. Not the cap. A single bidder who leaves the form blank rarely loses a lawsuit. It loses the tender.
Many forwarders route the questionnaire to sales. Or straight to the managing director. With no system behind it. The answers come from asking around. Who are our current subcontractors? Do they hold valid insurance? How much CO2 did the last run for this customer produce? Same questions, every year. Often from several large customers at once. Each in its own form. EcoVadis ratings ask for largely the same raw data. Just through a different portal.
Most of the raw material already sits somewhere in the operation. Just not in one place.
The subcontractor list lives in the TMS. Who drives which tour for whom is recorded there already. One export covers the first section of nearly every questionnaire.
The evidence documents usually sit as a PDF in a folder. Insurance certificate. License. Code of conduct self-declaration. With nothing tracking when they expire. That is exactly the case for a document register. Every document gets an expiry date as a field. A reminder fires before it lapses. The subcontractor gets a mail. Three weeks ahead. Automatically. Technically, that is the same problem as an access right nobody reviews. Just with a document instead of a login.
The emissions figure comes from the ISO 14083 pipeline. We build it for other customers anyway. Liters from the fuel card. Kilometers from telematics. Shipment from the TMS. One value per tour. Exactly the number a scope 3 questionnaire asks for. No second build. Same data chain.
The result is an export. Shaped to the customer's own format. Not to one standard form. There is no such form. The export pulls what the questionnaire needs from the register. And leaves out what the Value Chain Cap does not require anyway.
Sales stops treating the questionnaire as a special project. It pulls the export. And sends it back. In a day, not a week of research.
Subcontractor management gets a warning list. Every subcontractor with an expiring document shows up. Before the expiry date. Not after.
Dispatch gets a simple rule. No tour goes to a subcontractor without a valid document on file. Today, most operations only check that after something goes wrong.
Three honest limits.
Not every question in a questionnaire has a data answer. Some ask for a policy statement. A signature from management. A commitment to a principle. That stays manual work. A register supplies the numbers behind it. Not the text.
Not every subcontractor sends a digital document with a clear expiry date. Some send a scan with no visible date. Some claim indefinite validity. Then the only option is a manual follow-up. Once a year.
A complete register does not guarantee a good EcoVadis score. The rating also judges policies and process. Not only evidence on file. Automation supplies the basis for the answer. The position behind it is management's call. Not a script's.
A document register with an expiry date per piece of evidence. A reminder before expiry, sent to the subcontractor and to dispatch. A subcontractor list pulled straight from the TMS. An emissions value per tour from the ISO 14083 pipeline. An export shaped to whichever questionnaire format asked for it. None of it needs a new law that applies to the forwarder itself.
How many CSRD or EcoVadis questionnaires has your sales team answered this year? And how long did the last one take? Send me the number. I will show you, in a process check, the document register that answers the next one with an export.
