You are not required to report. Your largest customer is.
Many mid-sized companies reassure themselves with an entirely correct formal argument: not listed, below the thresholds, therefore not affected. Legally, that is often true. Operationally, it is a dangerous shortcut.
Regulation in an economy based on division of labour does not operate only where it starts. It affects large companies directly and everyone else through the supply chain. A group required to disclose emissions, energy and supply-chain data cannot invent it. It obtains that information from its suppliers and documents who provided it and who did not. [Evidence: status of Swiss climate-reporting regulation and the impact of EU rules on SMEs]
A rule that does not apply to you therefore becomes a line in the next tender form. At that point, it is no longer a question of attitude but of your ability to supply. A company unable to provide the data may be removed from the shortlist before price or quality is discussed. That is the quietest way to lose a customer: you never even learn that you were in the running.
The time horizon is crucial and routinely underestimated. A machine purchased today will still be on the factory floor in eight years and will then produce the figures you must disclose. A vehicle ordered today will shape the fleet’s footprint well into the 2030s. Investment decisions are therefore always reporting decisions as well, although that becomes visible only later.
The practical conclusion is that ESG and liquidity planning belong in the same discussion. When separated, the long-term argument regularly loses to the short-term one. When considered together, it often becomes clear that the more sustainable option is not more expensive over its useful life but needs to be financed differently.
A supplier uses leasing to invest in energy-efficient production because a major customer requires CO₂ data. The investment pays off through energy savings, order retention and reporting capability at the same time.
Has a customer already asked you for such data, and how long did the answer take?