Climate investors and buyers aren’t asking about women’s ownership
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With CSRD’s scope narrowed, your supplier questionnaire is about to get significantly shorter, and legally so. Starting with the 2027 financial year, you can no longer require a 400-person supplier to answer most of what you asked last year. That means your window into how they make the thing they sell you has shrunk considerably.
One gender question that survived the cut? You can still require that supplier to tell you how many of its employees are women. But what the standard doesn’t ask (and never did) is whether a woman owns the company.
I’ve written about why climate investors should care about that gap, and why corporate buyers should as well. Neither group is asking, and the reporting standard doesn’t ask either. In this article, I look at where gender sits in the new regulatory architecture, and where it doesn’t.
But first, a little background: Directive (EU) 2026/470 entered into force on 18 March, raising the CSRD threshold to companies with more than 1,000 employees and more than 450 million euros in sales. By most estimates, roughly 90 per cent of previously covered companies are now out of mandatory scope.
For those still in scope, what you can require of your suppliers is now capped, and those at or below 1,000 employees can decline requests that exceed the Commission’s Voluntary Standard (widely called the VSME). (It took effect 24 September, and the cap applies from the 2027 financial year.)
That ceiling is a fixed list of datapoints, set out in Annex II of the Commission’s delegated regulation, which is why the relief is real. Last year, small suppliers were being handed questionnaires built for companies many times their size. For companies still in scope, the revised ESRS cut total datapoints by more than 70 per cent, and the Commission expects reporting costs to fall by more than 30 per cent per company.
Here is what a buyer can still learn about gender at a supplier that size. The Basic Module asks for employee numbers by gender.
After that, visibility thins fast. A supplier reports its gender pay gap only where the law already demands one, which under the EU Pay Transparency Directive means 150 employees or more (100 from 2031). Women in management and on the board are optional disclosures, meaning that a buyer can ask, but it can’t insist.
For companies large enough to remain in full scope, the revised ESRS keeps the unadjusted gender pay gap mandatory when a company’s own workforce is material. The diversity focus narrows to gender distribution at the top management ranks.
In two decades of watching companies track what they say they value – first in workforce metrics and now sustainability data – I’ve learned to look at where a metric sits rather than just whether it exists. To that end, notice that each of these questions measures gender inside a company’s workforce, but none asks who owns the company.
The gap is widest where women-owned firms cluster. Women-owned businesses tend to be smaller than those owned by men, according to UN Women, and the smaller the supplier, the less the standard asks of it.
Large companies spend less than 1 per cent of their procurement budgets with women-owned enterprises globally, according to WEConnect International research cited by the International Finance Corporation. That is the baseline, and it has been a stubborn one.
Ask buyers themselves what they get from changing it, and the answer isn’t reputational. In IFC’s survey of 240 corporate buyers across six countries, the top-ranked benefit of gender-inclusive sourcing was better delivery performance and supplier reliability, ahead of alignment with sustainability and equality goals. Buyers newer to sourcing from women-owned firms put it at the top of their list.
That’s what thinning visibility costs. What doesn’t get requested doesn’t get tracked, and what doesn’t get tracked doesn’t get managed. A supplier attribute that buyers associate with reliability has no place in the standardised data exchange the EU has built for European companies (and the global companies supplying them).
Notably, a June report from CARE, Futerra and Project Dandelion, The $1 Trillion Blind Spot, reaches the same conclusion from the climate finance side, arguing that corporates “must use procurement, offtake and supply chain finance” to bring women-led enterprises into value chains.
As is so often the case with gender data, none of this requires building anything new. Certification bodies already hold verified ownership data and have for decades.
WBENC certification, for instance, requires that the business be at least 51 per cent owned by one or more women, who hold unrestricted control, demonstrate management of daily operations, and hold proportionate investment of capital or expertise. But this information lives outside the traditional sustainability data reporting stack.
Here are two ways to lean into the compounding power of female leadership:
I’m not suggesting the Commission add female ownership to the standard. (Indeed, it warns that any significant addition would weaken protection for small suppliers, and I agree.) Instead, I’m asking investors and buyers to ask one ownership question, which is far less than the emissions and water data buyers can already require.
In the end, your questionnaire is getting shorter, and that’s great. But this updated standard is a ceiling on what you can require, not on what you need to know to better support your own business.
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