Starting in 2026, thousands of companies across Europe will face a new reality: more detailed, more rigorous, and more transparent ESG (environmental, social, governance) reporting under the Corporate Sustainability Reporting Directive.
For logistics providers, transport operators, and supply chain participants, this directive represents a significant shift in how they measure, manage, and disclose their sustainability performance.
The logistics sector sits at a unique intersection of ESG concerns. Freight transport accounts for a substantial portion of global emissions. Warehouses consume energy at industrial scales. Supply chains span multiple countries, often with limited visibility into conditions several tiers down.
This article unpacks what CSRD is in the context of logistics operations, explains how the directive will reshape ESG reporting requirements, and provides a practical roadmap for logistics operators preparing for compliance.
CSRD at a Glance: What It Is and Why It Matters for Logistics
The Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464) significantly expands the scope of sustainability reporting compared to its predecessor. Where the NFRD applied to around 11,000 companies, CSRD will eventually cover approximately 50,000 companies operating in the European Union.
What Makes CSRD Different
The directive introduces requirements that fundamentally change how companies approach sustainability disclosure. The concept of double materiality stands at the core, requiring companies to report both how their operations impact the environment and society, and how environmental and social factors create risks or opportunities for the business itself.
Key features that set CSRD apart include:
Mandatory standardized metrics based on European Sustainability Reporting Standards (ESRS) developed by the European Financial Reporting Advisory Group
Third-party assurance of sustainability information, similar to financial audits
Electronic reporting using a tagged, machine-readable format
Broader scope covering environmental, social, and governance topics in detail
Double materiality requiring both impact and financial perspectives
These standards create comparability across companies and industries, ending the era where each organization could define sustainability metrics in its own way.
The Implementation Timeline
CSRD implementation follows a phased approach:
From 2025 onwards: Large public-interest entities already subject to NFRD (reporting on 2024 data)
From 2026 onwards: Other large companies meeting two of three criteria (more than 250 employees, €50 million turnover, or €25 million in assets)
From 2027 onwards: Listed SMEs, with some simplified requirements and an opt-out period
From 2029 onwards: Non-EU companies with significant EU operations
Individual EU member states are transposing the directive into national law, so specific timelines may vary slightly by country.
Why Logistics Companies Should Pay Attention
Logistics generates Scope 1 emissions from owned vehicles, Scope 2 emissions from warehouse electricity, and extensive Scope 3 emissions from subcontracted carriers and distribution networks. Few industries have such comprehensive exposure across all three emission scopes.
The position of logistics providers within supply chains creates additional pressure. A manufacturer reporting under CSRD needs emissions data from its logistics providers to complete its Scope 3 calculations. This creates cascading requirements where logistics companies not directly subject to CSRD still face demands from clients who are reporting under the directive.
Specific Impacts of CSRD on ESG Reporting in the Logistics Sector
The CSRD impact on logistics goes well beyond adding a sustainability section to annual reports. The directive will reshape data collection, operational processes, and client relationships across the sector.
Scope 3 Emissions Take Center Stage
For logistics operations, Scope 3 emissions often dwarf direct emissions. A freight forwarder might have minimal Scope 1 emissions if it owns few vehicles, but extensive Scope 3 emissions from the carriers it contracts.
CSRD ESG reporting requirements will push logistics firms to:
Track emissions across subcontracted carriers and third-party transport providers
Measure last-mile distribution impacts, including urban delivery
Account for upstream logistics in warehousing operations
Report modal splits showing the proportion of freight moved by lower-emission modes
Calculate intensity metrics such as CO₂e per tonne-kilometer or per shipment
This level of granularity requires data that many logistics providers currently lack or collect inconsistently. Logistics companies must report on emissions they don't directly control, creating a need to engage suppliers and carriers who may view detailed reporting as burdensome.
Data Collection Gets Serious
CSRD implementation demands a robust data infrastructure that goes far beyond spreadsheets and manual calculations. Fuel consumption needs to be broken down by vehicle type, route, and time period. Energy use in warehouses and distribution centers requires granular monitoring.
Telematics data showing actual vehicle performance, idle time, and routing efficiency becomes essential rather than optional. For cold chain operations, refrigeration metrics, including energy use and refrigerant leakage, must be tracked.
Many logistics companies will need to integrate data from transport management systems, warehouse management systems, fuel card programs, utility bills, GPS tracking, and supplier portals into a unified reporting framework.
Materiality Assessment in Logistics Terms
A double-materiality assessment requires companies to identify which ESG issues matter most to their specific operations. For logistics providers, this means evaluating impacts and dependencies particular to transport and distribution.
Material ESG topics for logistics operations often include:
Fuel and energy consumption from diesel, gasoline, natural gas, and electricity
Air quality impacts around distribution centers in urban areas
Noise pollution from night-time deliveries and warehouse operations
Packaging waste generated through handling and distribution
Labor conditions in warehouses and among drivers
Safety performance, including road accidents and workplace incidents
The materiality assessment process will require logistics companies to engage with internal teams across operations, fleet management, procurement, and HR, as well as external stakeholders, including clients, regulators, and local communities.
Supply Chain Transparency Becomes Non-Negotiable
Logistics networks are inherently complex, often involving multiple tiers of carriers and subcontractors. CSRD pushes for visibility into these relationships, particularly regarding ethical practices and ESG performance.
Logistics firms will need to map their carrier networks, collect data from subcontractors on emissions and labor practices, and verify ethical sourcing of transport services. Assessment of risks related to modern slavery, working hours, and fair compensation moves from optional due diligence to required disclosure.
This level of transparency requires new contractual terms with suppliers, data-sharing agreements, and potentially on-site audits or third-party verification.
Competitive Dynamics Shift
CSRD compliance will become a competitive factor in logistics. Large shippers subject to the directive will need detailed ESG data from their logistics providers to complete their own CSRD ESG reporting.
Conversely, logistics providers that build robust ESG data systems early can:
Win business from clients who need reliable sustainability data
Command premium pricing for services with verified low-emission profiles
Access capital from investors who favor CSRD-compliant companies
Improve operational efficiency through data systems built for compliance
Build resilience against regulatory and market shifts toward sustainability
The directive transforms sustainability from a nice-to-have differentiator into a basic requirement for competing in European markets.
Implementation Roadmap for Logistics Operators
Preparing for CSRD requires a structured approach. Logistics companies should begin planning now, even if their compliance deadline is several years away.
Step 1: Baseline Inventory and Gap Analysis
The first step is understanding the current state. Logistics operators need to map all operations and assess what ESG data they currently collect.
This means inventorying all operations covering owned and subcontracted transport, warehousing, cross-docking, and last-mile delivery. Existing disclosures should be reviewed, including any voluntary sustainability reports or client-specific ESG data already produced.
The gap analysis identifies where required information is not currently collected or is captured inconsistently. System capabilities need assessment to determine whether the current IT infrastructure can support CSRD requirements.
Step 2: Materiality and Stakeholder Mapping
Double materiality assessment requires input from diverse stakeholders. Internal workshops with operations, fleet management, procurement, HR, and finance teams surface different perspectives on what matters operationally and strategically.
External consultations with major clients, carriers, and industry associations reveal what stakeholders care about and expect. Impact assessment evaluates how the company affects the environment and society through emissions, resource use, and labor practices.
Risk assessment examines how environmental and social factors like fuel prices, climate events, and labor shortages create business risks or opportunities.
Step 3: Data Architecture and Collection Systems
With a clear understanding of what needs to be measured, logistics companies can build or upgrade data infrastructure. This often represents the most significant investment in CSRD implementation.
Required systems span multiple operational areas:
Fuel and energy tracking integrated from fleet cards and utility providers
Telematics platforms capturing vehicle-level data on consumption and routes
Warehouse management systems tracking energy use per square meter
Transport management systems calculating emissions by shipment and route
Supplier portals where carriers report their emissions and ESG metrics
HR systems capturing safety incidents, training hours, and turnover
Waste tracking for packaging materials and operational waste streams
The goal is to create a data flow that supports both operational decisions and CSRD ESG reporting without creating duplicate data entry work.
Step 4: Reporting Framework Alignment
CSRD requires alignment with European Sustainability Reporting Standards (ESRS) developed by EFRAG. The electronic reporting format uses tagged, machine-readable structures that enable automated analysis.
Calculation methodologies for emissions must use appropriate factors and conversion standards to ensure comparability. Logistics operators may benefit from working with sustainability consultants or accounting firms familiar with ESRS.
Starting this work early allows time to refine approaches before the first formal report is due.
Step 5: Governance and Assurance Mechanisms
CSRD requires clear accountability for sustainability information. Designated leadership, such as a head of sustainability or ESG committee with board oversight, provides clear responsibility at senior levels.
Internal controls similar to financial controls need documentation with defined processes and approval workflows. Quality assurance procedures to check data before publication catch errors and inconsistencies.
External assurance providers should be engaged early to understand requirements and timelines. Companies new to assured sustainability reporting should expect a learning curve in the first year.
Step 6: Embedding into Operations
The most successful approach to CSRD treats it not as a compliance exercise but as an operational improvement opportunity. The data collected for reporting should drive business decisions that improve both sustainability performance and operational efficiency.
Fuel efficiency programs can be informed by detailed consumption data that identifies inefficient routes or vehicles. Route optimization using the same data that feeds emissions reporting reduces both fuel costs and environmental impact.
When sustainability metrics connect to operational KPIs and management incentives, the reporting process becomes a tool for genuine improvement rather than an administrative burden.
Step 7: Supply Chain Partner Alignment
Logistics networks depend on multiple tiers of carriers and subcontractors. CSRD compliance requires engaging these partners to ensure they can provide the necessary data and meet the expected standards.
Contractual requirements for ESG data provision set clear expectations from the start of relationships. Supplier onboarding programs help smaller carriers understand what is needed and why.
Data templates and portals that simplify reporting for smaller carriers reduce friction and increase response rates. Larger logistics providers may need to support smaller carriers in building their own data collection capabilities.
Step 8: Monitor, Disclose, and Refine
CSRD compliance is not a one-time project but an ongoing process. Logistics companies should establish regular monitoring of ESG metrics and continuous refinement of data collection and reporting.
Key performance indicators for logistics include:
Emissions intensity measured as CO₂e per tonne-kilometer
Modal split showing the percentage of freight by road, rail, sea, and air
Renewable energy use as a percentage of warehouse electricity
Fleet efficiency tracking fuel consumption per distance
Safety performance, including accident rates and lost-time injuries
Supplier compliance showing the percentage of carriers providing verified data
Waste diversion measuring the percentage of materials recycled or reused
Tracking these metrics over time allows logistics operators to demonstrate improvement and adjust strategies based on performance.
Moving Forward with CSRD
The Corporate Sustainability Reporting Directive represents more than a new regulatory requirement for logistics companies. CSRD implementation will fundamentally reshape how logistics firms collect data, make operational decisions, and engage with clients and supply chain partners.
Companies that start now can build data infrastructure at a manageable pace, engage suppliers early, and use the process to identify operational improvements. The CSRD impact on logistics extends beyond direct regulatory compliance, creating competitive advantages for early movers.
Logistics operators should assess their readiness, engage stakeholders across their operations, and build realistic plans for 2026 and beyond. Companies that treat CSRD as an opportunity will find themselves better positioned as sustainability transparency becomes standard practice.
