ESG disclosure: what has to be published, and by whom

ESG disclosure is the publication of information about environmental, social and governance performance — emissions and resource use, workforce and safety, board structure and business conduct. It began as voluntary reporting by large listed companies and is now, in several jurisdictions, a legal obligation with defined scope and timing.

For a small business the direct obligation usually does not apply. The indirect one increasingly does: a large customer subject to disclosure rules has to report on its value chain, which means asking suppliers for numbers. That request is how most small companies encounter this, and it arrives with a deadline attached.

The three letters, concretely

• Environmental: energy, emissions, waste, water, materials. Emissions are usually split into direct, purchased energy, and everything else in the value chain — that third category is where a supplier request lands.
• Social: employment practices, health and safety, training, diversity, and how you treat people in your supply chain.
• Governance: ownership and board structure, anti-bribery and conduct policies, data protection, and how decisions are controlled.
• The unglamorous truth is that most of what a small supplier is asked for already exists somewhere — energy bills, headcount, incident records, policies — and the work is collation rather than measurement.

Preparing before you are asked

1. Find out whether your largest customers are subject to disclosure rules. If they are, a request is a matter of time.
2. Collect the boring baseline: energy use from bills, headcount and turnover, incidents, and which policies you actually have. A year of history is worth more than a sophisticated method.
3. Write down the policies you claim to have. Requests ask for documents, and having the practice without the document reads as not having it.
4. Name an owner. Disclosure requests arrive at whoever answers the phone, and they need somewhere to go.
5. Keep the evidence with the figure, which is the part that makes next year cheap rather than another archaeology exercise.

Answer only what you can evidence. A supplier questionnaire is easier to complete optimistically than accurately, and the answers become contractual representations that somebody may later audit. Not measured yet is an acceptable answer that costs you nothing; a figure you cannot substantiate is a liability you have created for free.

Where the rules are going

The direction across major regimes is towards more disclosure, more standardisation and more assurance, with thresholds moving down over time and value-chain reporting pulling smaller suppliers into scope indirectly. The specific timetable, thresholds and content vary substantially by jurisdiction and have been repeatedly revised, so the only responsible statement here is that this is worth checking annually against your own regulator rather than assumed from an article. The frameworks themselves are covered in sustainability reporting standards.

Where it lives

Ettex Records holds the figures, their evidence and their owners as structured entries — which is what turns an annual scramble into a lookup — with the published document in sustainability report and the arithmetic in Ettex Sheets. Supplier requests going the other way connect to supplier onboarding.

To be clear: we do not calculate emissions, do not map data to frameworks, do not collect supplier data and do not provide assurance. Nothing here is legal or regulatory advice; where a rule applies to you, the applicable regulator and a qualified adviser are the sources that matter.