How Pakistan Supply Chain Data Feeds Into Your CSRD Sustainability Report

This article is about making that consolidation work for Pakistan-origin data specifically.

What ESRS E1 requires that involves Pakistan

The European Sustainability Reporting Standards E1 on climate require several disclosures where Pakistan supply chain data is directly relevant.

ESRS E1-6 on Gross Scopes 1, 2, and 3 GHG emissions requires disclosure of Scope 3 emissions, including Category 1 (purchased goods and services). For a brand sourcing textiles, garments, or home goods from Pakistan, the production emissions of Pakistani suppliers are the primary content of Scope 3 Category 1.

ESRS E1-9 on anticipated financial effects of climate-related risks requires description of the financial impacts of physical climate risks in the value chain. Pakistan's flood risk (2022's USD 30 billion flood damage), water stress in manufacturing regions, and extreme heat risk affecting worker productivity and equipment operation are physical climate risks in your Pakistan supply chain that require disclosure.

ESRS E1-1 on transition plan requires describing what actions the company is taking to reduce its GHG footprint including supply chain. Actions with Pakistani suppliers, supporting their renewable energy investment, requiring verified GHG inventories, facilitating climate finance access, are relevant actions to describe.

The supplier data quality problem: what your auditor sees Your statutory auditor reviewing your CSRD disclosure will assess the quality of your Scope 3 data. They will ask: where did this Scope 3 Category 1 number come from? What is the quality of the underlying data?

For a disclosure that says "our Scope 3 Category 1 is X tonnes CO2-equivalent," the auditor's follow-up questions are specific.

For data from verified third-party GHG inventories: what methodology was used? Who verified it? Was the verifier qualified? Is the verification statement available? These questions have clean answers when the supplier has a properly verified GHG inventory from a competent verifier.

For data from supplier self-declarations: what methodology did the supplier use? Were they calculating Scopes 1, 2, and relevant 3? What emission factor did they use for Pakistan grid electricity? Did they account for captive generation? The answers are often "we don't know" or "the supplier didn't specify," which is exactly what creates data quality issues in the disclosure.

For data from proxy emission factors (industry-average databases): the auditor will accept this as a recognized methodology for suppliers where specific data isn't available, but it will be noted as lower-quality data. Your disclosure will need to acknowledge the proportion of Scope 3 that is based on proxy factors versus supplier-specific data, and describe your plan to improve data quality over time.

What a properly verified supplier inventory looks like in a CSRD disclosure

Consider a Pakistani textile mill that commissions a multi-year verified GHG inventory with a qualified independent verifier. This is exactly the kind of supplier data that CSRD auditors can work with.

A properly verified inventory covers multiple consecutive fiscal years under the GHG Protocol Corporate Accounting and Reporting Standard, conducted by an independent third-party verifier, with a verification statement confirming the inventory was prepared in accordance with the methodology and that the verifier found no evidence of material misstatement.

For a buyer sourcing from a supplier with this kind of data, verification provides:

A verified baseline covering multiple years, allowing year-on-year trend analysis of genuine, auditable emission reductions rather than a one-off snapshot.

A per-unit GHG intensity figure (tonnes CO2-equivalent per kilogram or per metre of production) that the buyer can multiply by their purchase volume to get a supplier-specific Scope 3 Category 1 number.

A verification statement that the buyer's auditor can point to as evidence of data quality, and trajectory data that supports the supplier's own decarbonisation roadmap, which the buyer can reference in their own transition plan disclosure.

This is what "good quality Scope 3 supplier data" looks like. Compare it to a supplier who sends an email with "our annual electricity consumption is approximately 5 million kWh and our gas consumption is about 2,000 MMBtu" without any methodology, emission factors, or verification.

Building the supplier data collection programme

Systematizing high-quality Scope 3 data collection from Pakistan suppliers requires a three- stage approach.

Stage one: categorize your supplier base by data readiness. Which suppliers have verified GHG inventories? Which have calculated but unverified inventories? Which have no measurement infrastructure?

Stage two: set a roadmap with timelines. For top-tier suppliers (highest volume, longest relationship), require verified GHG inventory data within 18 months, with interim self-declaration using documented methodology as an acceptable bridge. For other suppliers, require at minimum a methodology-documented self-declaration (which emission factor, which boundary, which scope) within 12 months.

Stage three: provide support rather than just demands. Connect suppliers with GHG inventory development resources (Tti Labs' Sustainability Center can provide GHG inventory development and verification for Pakistani suppliers). Facilitate their access to green banking finance for the measurement infrastructure investment. Share the emission factors they should use for Pakistan grid electricity rather than leaving them to find it themselves.

For supplier GHG inventory development and verification to support CSRD Scope 3 data quality, contact Tti Labs Sustainability Center at sustainability@ttilabs.net.