30 Tier 1 suppliers. Over 200 Tier 2. All of it collected the same way: a questionnaire, sent out by procurement, timed to land right before contract renewal.
That was the Scope 3 data collection process behind one ESG Readiness Assessment we ran recently, for an EPC company in the renewables sector, a business whose entire market position is built on the fact that it's building the clean energy transition.
The Environment section of the assessment had 81 questions. 75 came back "Not Applicable." Of the six that weren't, none had supporting evidence attached: no data, no audit, no document trail. Just a checkbox.
Run the same assessment on the company's own suppliers and the pattern held one level down. No Scope 1 or 2 emissions data. No water strategy. No biodiversity assessment. Where a policy did exist, on diversity, on health and safety, on anti-corruption, the answer was an honest "Yes." Not one "Yes" had proof behind it.
A "Yes" nobody has ever had to defend isn't a policy. It's a guess wearing a policy's clothes.
This is where it stops being a paperwork problem and becomes a double materiality problem. Most local and national reporting frameworks now ask two separate questions, not one.
Financial materiality asks whether an issue could affect the company's own performance, financing, or risk. Impact materiality asks whether the company's own activity affects people or the environment enough to warrant disclosure.
An unverified "Yes" fails both at once. On the financial side, a lender, insurer, or acquirer who later finds no evidence behind the Scope 1, 2, or 3 numbers doesn't just uncover a data gap; they get a reason to reprice risk or walk away. On the impact side, a claim that turns out to have no substantiation isn't a disclosure gap under most regimes. It's a false or misleading statement, carrying its own reporting and liability consequences separate from the ESG numbers themselves.
Nobody in this story was lying. But look at who was actually collecting the data, and when. Procurement, right before renewal, from a supplier who wants the contract renewed. That isn't a data-quality problem. That's asking the person with the least incentive to say no to be your only check, on both sides of the materiality question at once.
A questionnaire isn't due diligence. It's a paper trail that looks like due diligence until someone, a regulator, an auditor, a client's own compliance team, actually asks for the evidence behind it.
If a company building renewable infrastructure can't prove its own supply chain's ESG claims, what does that say about the claims sitting behind everyone else's?