Climate reporting now affects you and your suppliers
Mandatory climate disclosure is bringing marketing supply chains into annual reporting. The useful question is whether buyers can see the emissions attached to a purchase before they commit to it.
Your biggest customer may soon ask for emissions data you can’t easily provide. Your bank or board may have questions too. For marketing teams, answering them means tracing the footprint of print, signage, merchandise, packaging and campaign freight, often bought through a mix of agencies and suppliers.
Australia’s mandatory climate reporting requirements began phasing in for the largest entities for financial years starting on or after 1 January 2025. The second group follows for financial years starting on or after 1 July 2026. From a reporter’s second year, the requirements extend to Scope 3 emissions across its value chain. The scale is substantial: CDP and BCG’s 2024 analysis found that disclosed supply chain emissions averaged 26 times a company’s operational emissions.
Marketing purchases are part of that footprint, but the information behind them can be difficult to pull together. A quote tells you the price and delivery date. It may tell you very little about the emissions involved. Closing that gap would help with reporting and give buyers more information to work with.
How your suppliers become part of your reporting
A business doesn’t have to fall within the reporting thresholds to feel the effect. Its larger customers may ask for emissions data to help calculate their own Scope 3 footprint. ASIC makes clear that these requests can reach small and medium-sized suppliers, although reporting businesses can also use estimates and industry averages where appropriate.
There is a familiar precedent in modern slavery reporting. Many suppliers first encountered it through customer questionnaires and contract clauses, even when they had no reporting obligation themselves. Climate reporting can create similar requests. The difference is the kind of answer needed: customers will want figures they can use and an explanation of how those figures were calculated.
Even if your business doesn't have to lodge a report, a major customer may still ask for emissions data.
Why marketing spend is difficult to measure
Energy use can be read from a meter. Fleet data is often already tracked. Marketing procurement is more fragmented, as we see in day-to-day work. Agencies, printers, freight providers and merchandise suppliers are organised around delivering campaigns, often to tight deadlines. They don’t necessarily record emissions in the same way. With forty suppliers, you could be reconciling dozens of methods and different definitions of what has been counted.
This is a widespread problem. CDP and BCG’s 2024 analysis found that companies were twice as likely to measure operational emissions as supply chain emissions. Only 15% of companies disclosing to CDP had set a supply chain emissions target.
Spend-based estimates offer a starting point, but they have limits. Because the calculation relies on expenditure and emissions factors, it may miss the benefit of choosing a lower-emissions material. Two products at the same price can have different footprints without that difference appearing in the estimate.
Give buyers the data before they order
Buyers already weigh up price, availability and delivery time. Emissions data can become part of that decision if it arrives early enough and is comparable across the options. That’s the practical value of decision intelligence: giving people useful information while they can still act on it.
Take two quotes for the same campaign item, using different materials or freight options. An emissions estimate beside each price helps the buyer assess the trade-offs before placing the order. A figure assembled from invoices at year-end can support reporting, but it comes too late to influence those purchases. Buyers also need to understand what each estimate includes so they can make a fair comparison.
A footprint isn't set at year-end. It's set one purchase order at a time.
Why it is worth preparing now
There are understandable reasons to wait. Many mid-sized organisations sit below the reporting thresholds. The 2026 Federal Budget proposed higher financial reporting thresholds that would also remove sustainability reporting obligations for some proprietary companies. Certain early Scope 3 disclosures also receive temporary modified liability protections. If you may never have to file a report, preparation can look like work that can wait.
The more immediate issue may be what your customers need. Their reporting timetable can create requests for data before your business has any direct obligation. Agreeing on methods with suppliers, updating contracts and collecting usable information all take time.
There is a commercial reason to prepare as well. When emissions data forms part of a tender, a supplier with credible figures is easier to assess. Waiting until a customer asks can leave you trying to resolve gaps while a contract decision is already underway.
Better supplier relationships can improve the data
Working with fewer suppliers can make reporting easier, provided those suppliers can produce reliable information. CDP identifies supplier engagement as an important driver of progress on supply chain emissions. In practice, closer working relationships can make it easier to agree on methods, resolve gaps and keep records that can be checked.
Consolidation alone won’t improve data quality. What matters is whether you and your suppliers are working to a consistent approach. If you’ve already consolidated marketing procurement for cost or control, it’s worth checking how much of that work could also support Scope 3 reporting.
Five questions for the CFO and CMO
- Which reporting group, if any, covers our organisation or parent company, and when does the second reporting year begin?
- Which major customers are in scope, and what emissions data are they likely to request from us and when?
- What credible emissions data can we produce for marketing spend today, and how much relies on spend-based estimates?
- Who is responsible for Scope 3 data in marketing procurement, and how do sustainability, finance and buying teams contribute?
- Can the people placing orders see emissions estimates before they decide, or only when the report is prepared?
Make the reporting work useful
Preparing for Scope 3 means understanding who supplies your marketing materials, what data they can provide and how reliable it is. That work can also help buyers understand the emissions associated with their material and freight choices.
The practical aim is to make the information useful to the people spending the budget. Put comparable emissions estimates alongside price and delivery time, and buyers can consider them while they still have a choice. You’ll also be better placed to answer the next customer questionnaire without rebuilding the picture from scratch.
What would your marketing spend report?
Talk to us about putting carbon data on your quotes — before someone asks for it.
