Which customers will shape your sustainability priorities in the years ahead?

At first glance, this appears to reduce pressure on mid-sized and smaller companies.

In practice, it changes where that pressure originates.

For many companies outside direct regulatory scope, sustainability expectations will now flow primarily through customers rather than regulators. And in several sectors, this shift is already visible.

What is customer-driven sustainability?

Customer-driven sustainability is the process where companies are adjusting their sustainability approaches based to the requirements set by their current and potential customers.

Europe’s major construction companies and retailers are a clear example. They are translating their own regulatory, investor, and strategic commitments into contractual requirements for suppliers, thereby raising the sustainability bar.

Suppliers are now required to demonstrate, among other things:

• Environmental Product Declarations and credible, customer-specific product carbon data
• EcoVadis or CDP disclosure as a prerequisite for doing business
• Science Based Targets initiative aligned carbon targets
• Certified management systems such as ISO 9001, 14001, and 45001
• Sustainably sourced wood, fiber, and materials with verified chain of custody
• Evidence-based sustainability due diligence across operations and supply chains
• Documented results from implemented sustainability actions and clear forward-looking plans

This is not cosmetic positioning.

It is how stakeholder expectations, corporate strategies, and regulations such as CSRD, ESRS, CSDDD, and the Construction Products Regulation manifest in day-to-day procurement decisions.

In other words, the strategic choices, identified impacts and regulatory pressure are transmitted through value chains.

For suppliers, the relevant question is no longer “How can we offer the best price, quality, and delivery reliability to win and keep the customer? “ but also “What is required from our sustainability management system to meet the expectations of the target customers?“

A three-speed sustainability environment

The Omnibus recalibration creates a clearer segmentation across large-scale, medium-scale, and small-scale enterprises.

Large-scale enterprises remain directly accountable for transparency, due diligence, and measurable performance. Their sustainability systems are embedded in governance, investor relations, and strategy.

Medium-scale enterprises operate in a conditional space. Formal reporting requirements may be lighter, but if revenue depends on large customers under scrutiny, expectations cascade downward. In sectors like construction and retail, this is already happening at scale.

Small-scale enterprises may sit outside formal reporting thresholds, but they increasingly encounter structured sustainability questions during supplier onboarding and contract renewal. Sustainability performance becomes part of qualification criteria rather than a voluntary add-on.

The practical implication is that sustainability is integrating into the value proposition as ambition is increasingly shaped by value chain position rather than company size alone.

Why construction and retail are leading indicators

Construction and retail are particularly illustrative because sustainability requirements are becoming embedded in core product specifications.

In construction, carbon intensity, material traceability, and verified Environmental Product Declarations are increasingly prerequisites for project participation. Large contractors must quantify the embedded emissions of buildings and infrastructure. They cannot do so without supplier-level product data.

Retailers face similar dynamics. Public commitments on emissions, sourcing, and circularity require granular data from suppliers. Procurement teams are under pressure to demonstrate that sustainability claims are substantiated with evidence.

For SMEs supplying into these ecosystems, sustainability capability directly affects eligibility.

This is not theoretical future risk. It is operational reality in tender processes today.

What this means for SMEs seeking growth

For SMEs aiming to grow with large, listed construction companies or major retailers, sustainability maturity becomes commercially material.

Customers increasingly expect suppliers to demonstrate:

• Clear sustainability ambition aligned with recognized frameworks
• Measurable progress against defined targets
• Structured, continuously improving management systems
• Credible, documented evidence supporting claims

Without these elements, participation in higher-value contracts becomes more difficult.

The consequence is not necessarily immediate exclusion, but reduced competitiveness. In procurement scoring models, sustainability performance can determine who advances to final negotiation rounds.

SMEs that invest early in proportionate but credible systems position themselves for preferred supplier status. Those that remain reactive often face compressed timelines when requirements become contractual.

Market momentum reinforces this shift

Beyond sector-specific examples, broader market signals reinforce the customer-driven dynamic.

Today more than 150 000 companies are EcoVadis rated. In 2025, more than 270 major buyers requested sustainability data from approximately 45,000 suppliers through CDP. Meanwhile, 640 investors representing over US$127 trillion in assets asked CDP to collect the data they rely on for capital allocation decisions. More than 10,000 companies globally now operate with validated science-based targets.

These commitments create downstream effects. When a listed company sets a validated emissions reduction target, it must measure and reduce Scope 3 emissions. That reduction cannot happen without supplier engagement.

The pressure moves outward through the value chain.

Aligning sustainability ambition with commercial exposure

In this three-speed environment, sustainability ambition should reflect commercial exposure rather than regulatory fear.

If your revenue model and growth depends on large size enterprises under sustainability scrutiny, building structured sustainability capability becomes a growth enabler. It supports access to contracts, strengthens long-term customer relationships, and reduces friction in procurement.

If your customer base operates in markets with lighter sustainability expectations, your urgency may differ. However, even in those contexts, sustainability systems can improve operational efficiency, resilience to input volatility, and attractiveness to employees and lenders.

The strategic risk lies not in choosing a lower ambition level, but in failing to understand how exposed your business model is to customer-driven expectations.

Building viable systems, not excessive infrastructure

For SMEs, the objective is not to replicate the complexity of multinational sustainability departments.

It is to build fit-for-purpose systems that can:

• Collect accurate data
• Document processes and controls
• Demonstrate progress over time
• Respond confidently to customer and investor requests
• Credibility increasingly depends on documented evidence rather than narrative commitment.

As procurement criteria evolve, sustainability management systems become part of commercial infrastructure, similar to quality or safety certifications.

The reward: preferred supplier status

The construction products market and adjacent retail sectors are integrating sustainability into core business requirements at pace.

SMEs that treat sustainability as a structured, continuously improving management discipline can position themselves as preferred suppliers. That status supports contract stability, deeper partnerships, and participation in higher-value projects.

Sustainability, in this context, is not primarily a reporting burden. It is a qualification threshold and, increasingly, a competitive differentiator.

The strategic question ahead

Regulatory scope may determine minimum obligations. Customer strategies and exposure increasingly determines competitive requirements.

For SMEs and medium-scale enterprises across Europe, the critical question is not whether sustainability applies. It is how deeply your revenue streams depend on customers who expect you to demonstrate measurable sustainability performance themselves.

Understanding and aligning your sustainability ambition and systems accordingly, will shape commercial opportunity in the years ahead. And if you want a roadmap to help you plan your roadmap in line with said ambition, we have just the resource for you.