Assistance with reporting on your value chain

Sustainability reports edited according to European reporting standards will have to provide insights into your company’s value chain, in addition to company-specific information. This poses quite a challenge for reporting organizations, but is nonetheless extremely important. After all, a broad overview of your value chain gives a more complete understanding of your ESG-related impacts, risks and opportunities. At the same time, Europe hopes to achieve a snowball effect with the CSRD, and also push companies towards more sustainable business operations outside of its scope. Closer contact with stakeholders throughout your value chain, including on their policies and ESG data, contributes to this.

December 10, 2024
CSRD general

For some time, EFRAG has been developing guidance to facilitate the implementation of the ESRS and double materiality analysis. The documents provide practical guidance on implementing the ESRS, although they are not mandatory. A first guideline was the Materiality Assessment Implementation Guidance (MAIG), the highlights of which can be found here. The explanations from the MAIG are complemented by the Value Chain Implementation Guidance (VCIG), the subject of this article. The VCIG provides methods and advice for including your value chain in the materiality assessment. Let’s get started!

What is your value chain, and why would you report on it?

For many companies this is something of a novelty: reporting on elements outside their own consolidated financial statements. Europe and EFRAG are now opening up that scope to the entire value chain, which they define as all activities, resources and relationships on which the company relies to create its products or services, from design to delivery, consumption and end-of-life. This therefore includes both upstream and downstream actors, and both direct and indirect contractual relationships.

Reporting on your value chain is important because a large portion of your IROs are not within your own operation, but in the activities of your business relations. An example: a European company trades toys manufactured outside the EU, where legal requirements are less stringent. Among other things, dust and chemicals in the manufacturing process pose various risks to the environment, health and safety. This obviously affects employees, but also local communities around the factory. From a financial materiality perspective, the European company may have to expect stricter compliance with laws, or even fines.

Value chain or supply chain?

One deliberately uses the term ‘value chain’ instead of ‘supply chain’ (annex 2), to put the impacts, risks and opportunities of downstream activities on an equal footing with those of upstream activities. Indeed, a supply chain view focuses more on the supply side,and thus on upstream activities. Specifically, the supply chain is part of the value chain, but the two terms are not synonymous.

What should you report, and which stakeholders do you take into account?

The definition of your value chain makes it immediately clear: there are countless actors involved in your value chain. Asking them all about their ESG policies and data is nigh on an impossible task. That is why EFRAG makes it explicit that your sustainability statement should provide information on the material IROs of your value chain.

So you find that the materiality analysis recurs again and again as a cornerstone of your ESG strategy, and therefore for everything related to your value chain. In your materiality analysis, you identify where the IROs are that are likely to be material. You do this geographically, according to your activities and sector, in your own business operations and with obvious business partners,such as your suppliers, customers or other groups.

You could already read about the exact steps you follow in the materiality analysis to determine your IROs in this insight. Today we take a closer look at the stakeholders (value chain actors) with whom you determine that materiality. Here, EFRAG puts forward two major groups that you can realistically expect to be associated with material IROs:

  1. Actors most likely to have impacts on people and/or environment from detected hot spots
  2. Actors on which your own business model depends, e.g. in relation to products or services

Some special cases among stakeholders

The standards in the S pillar ESRS S2 Employees in the value chain, ESRS S3 Affected communities and ESRS S4 Consumers and end-users provide a specific reporting framework on material IROs related to these groups in your value chain. These standards do not specify default metrics, although the ESRS does require you to establish entity-specific metrics where necessary.

When associates or joint ventures are part of your value chain, for example as suppliers, you include information on them in the same way as on other business relationships. When calculating specific metrics, data on these types of actors are therefore not limited to the equity share. Indeed, they are taken into account based on the impacts associated with your products and services through business relationships.

Regarding investments, there is a table (p. 11-12) that clarifies how impacts arising from investments should be included in both financial reporting and the sustainability report.

Do you have additional questions on how specific groups should or should not be included in your value chain approach? Feel free to contact us at mail@pantarein.be.

You need to specifically provide the following info about your value chain

To contain the reporting burden on your value chain, the EC decided to only make information related to material IROs mandatory. The standards mainly require disclosures on your policies, targets and actions related to your value chain. This allows you to use selection criteria for new suppliers, develop actions to tackle waste management downstream, set targets related to respecting human rights, etc.


Within the metrics, only a handful are mandatory for the entire value chain. The most important of these is probably your carbon footprint, which requires you to disclose your Scope 3 GHG emissions. Even though a limited number of other metrics are imposed for the value chain, the guidelines do require you to determine for which proprietary material topics additional metrics are desirable.

Estimates and postponements

EFRAG and Europe understand that it is not always easy to obtain the necessary value chain data (e.g. because there are few contractual commitments with an indirect business partner, or because it concerns an SME that does not have a structural ESG policy). In that case, you have to make an estimate, based on internal and external information, sector averages, samples, and peer data, among other things. Incidentally, one major boon for SMEs will be the introduction of proportional standards (a mandatory standard for listed SMEs and a voluntary one for non-CSRD-regulated SMEs). Those derived standards will clarify what data CSRD players can request from SMEs.

Know that the general transitional provisions allow a three-year postponement to collect value chain information. However, you should explain the efforts you have made to obtain the information, the reasons why this has not been successful, and what you will do about this in the future.

Finally, realize that by including your entire value chain in your ESG policy and reporting, you can leverage your network. That is what Europe hopes will happen, anyway. Say you are a big supplier or buyer, you can really influence certain actors. Thus, the ESG report becomes a tool with real impact.

Not started working on your value chain yet? We would be happy to help you. Contact us at mail@pantarein.be.