Responsible Procurement: Guide & 2026 Impact

The Omnibus package was published in the EU Official Journal on 16 December 2025 and takes effect on 18 March 2026. It overhauls the eligibility thresholds: to remain within mandatory CSRD scope, a company must now exceed 1,000 employees and €450M in net revenue. The two criteria, previously alternative, are now cumulative. In numbers: around 80 % of originally targeted companies exit the scope, and the European perimeter contracts to roughly 10,000 groups^[1]. The ESRS reporting standards are trimmed by roughly 60 %.

The obvious conclusion ("less regulation, therefore fewer sustainable purchases") misses a critical point. Large companies that remain under CSRD still have to document their value chain, including Scope 3 emissions and the social practices of their suppliers. To collect that data from SMBs now outside the scope, EFRAG designed the VSME (Voluntary Sustainability Reporting Standard for SMEs): a voluntary, modular framework that enterprise customers can legitimately request from their sub-contractors^[2]. In plain terms, the obligation moves up one level. It no longer falls directly on the supplier. It comes back to them through their customer.

Before reaching for a criteria spreadsheet, you need a framework. The most widely adopted is ISO 20400:2017, guidelines for responsible purchasing built on ISO 26000. It covers the environmental, social, ethical, and economic dimensions of procurement, applies to any organization regardless of size, and helps leadership define a policy and a strategy^[3]. One methodological point that often gets missed: ISO 20400 is not a certifiable management system like ISO 9001 or ISO 14001. You don't "get certified" against it. You align with it. Any company claiming an "ISO 20400 certification" is being misleading.

In practice, ISO 20400 structures the approach in four stages: foundations (vision, policy, ambition), governance and strategy (integration into procurement processes), putting it into practice (specifications, selection criteria, weighting), and finally measurement and improvement (KPIs, review cycle). It's that last stage where digital tools earn their keep: without supplier-level data flowing in, without consolidated reporting, a policy stays a statement. To map the carbon impact chain alongside this, our practical guide to Scopes 1, 2 and 3 fills in the picture.

Responsible procurement starts with clauses written into contracts. In public procurement, Article 38 of the 2015 ordinance (and Article 62 of the implementing decree) allows the inclusion of performance clauses with a social purpose: integration hours, engagement of work-integration social enterprises, employment of people distant from the labour market^[4]. Private sector buyers borrow freely from this model. These clauses translate without difficulty into B2B contracts.

The two mechanisms complement each other. A performance clause governs conduct during the contract; an award criterion weights the supplier selection upfront. A serious buyer combines both: CSR approach is scored at the RFP stage, then commitments are locked in through a performance clause. National targets set explicit ambitions: 100 % of public contracts to include an environmental consideration, 30 % a social one^[4]. These are indicative targets, but they define the expected standard.

Once the policy is in place, you still face the question of "how do I compare two suppliers?" The answer lies in CSR scoring. Several players have become standard: EcoVadis produces a score out of 100 benchmarked against sector peers; the RFAR label (Responsible Supplier Relations and Procurement), overseen by France's business mediator at the Ministry of the Economy, certifies the maturity of a procurement function^[5]. Lucie and B Corp cover broader scopes but apply to suppliers too. The right approach isn't to mandate a single tool, but to set a threshold: "EcoVadis score ≥ 45, or equivalent label".

Scoring only has value if it influences decisions. The classic mistake is to collect scores and then set them aside in favour of price. An explicit weighting grid (for example 50 % price, 20 % quality, 20 % CSR, 10 % lead time) forces trade-offs to be made against stated criteria rather than gut feel. That's also what turns a CSR approach into a genuine procurement lever: it becomes a management criterion, not a communications exercise.

There is an angle most procurement teams overlook: the payment method itself. A corporate card is not neutral: it traces every transaction, consolidates spend by supplier, and, in the case of the Greenway card with the 1%ForAll® programme, donates 1 % of every payment to the Greenway Foundation. The impact becomes measurable, tied to real spending, not a promise. That is precisely the fourth stage of the ISO 20400 cycle: measurement.

This mechanism is doubly interesting for procurement teams. First, because it turns a support function (payment) into an impact sensor, with no extra process: the data already exists and feeds directly into reporting. Second, because it answers the downstream pressure described above: an enterprise customer asking a supplier for a VSME report appreciates a partner who produces documented impact rather than declarations. To connect this logic to the broader CSR and compliance framework, our CSR & CSRD white paper lays the groundwork.