WorkflowCorporate Strategy & ESG

The complete guide · November 2026

ESG questionnaire response, explained.

Rating firms, hospital buyers and investors keep sending drug makers long forms about their environmental, social and governance (ESG) record: how much carbon they emit, where they draw water, who audits their suppliers. Each form asks much the same things in different words, and the same people answer them all year. This guide explains that work, why one emissions figure can end up with three different values, and how to keep every answer true.

This guide is for the people who answer these forms: ESG reporting leads, environment, health and safety (EHS) directors, procurement sustainability leads, lawyers who review environmental claims and key account teams. It is also for the leaders deciding whether to automate the work. No background needed.

See one case, screen by screen →
Watch with transcript →
A quick example · fictional

Imagine you are the ESG reporting lead at Northwind Bio, a mid-size drug company. It is Wednesday, October 7, 2026. Five sustainability questionnaires are already open, and Sam, the key account director who looks after your large customers, has just forwarded a sixth: 18 questions from a group purchasing organization, the buying club hospitals join to get better prices. It is due November 12.

One question asks for your 2025 greenhouse gas emissions from your own sites and the energy you buy, known as Scope 1 and 2. The usual way to start is to open last spring's answer to a customer called Merrow Health and copy it. That answer says 61,400 tonnes. It was a preliminary number.

You sold a plant in February, and in June your emissions inventory, the yearly tally of those gases, was recalculated. An independent firm has checked the new figure, a step called assurance, and page 22 of your published report now says 58,920. The old figure also sits in two of the questionnaires already open.

What the copied answer says
2025 Scope 1 and 2
61,400 tonnes
Written
Mar 20, 2026
Status
Preliminary
Claims
"Verified"
What the assured inventory says
2025 Scope 1 and 2
58,920 tonnes
Restated
Jun 2026
Status
Limited assurance
Assured on
May 29, 2026
Gap of 2,480 tonnesOne customer already has the old figureThat old answer also said "verified" two months before any assurance.

Further down the same file sits a question about carbon neutrality. Your old spreadsheet answers yes, since 2022, through offsets: credits bought for emission cuts made elsewhere. Those purchases ended on January 1, 2026, and your own climate transition plan now says the company does not use that phrase.

This work catches both before the new file goes out: the old figure in every open questionnaire, with a correction note for the customer who already has it, and the claim your evidence no longer supports.

ESG questionnaire response guide
Part A · Understand it

Who sends ESG questionnaires to a drug maker, what they ask, and which rules stand behind them

What these questionnaires are, the rules and their status on November 3, 2026, why emissions figures drift, what a carbon-neutral claim now risks, the common errors and the published numbers. If you are new to sustainability reporting, start here.

01 · In plain words

What an ESG questionnaire asks of a drug company, in plain words

ESG stands for environmental, social and governance: a company's effect on the planet, how it treats people, and how it is run. Outsiders want to know about all three. A rating firm wants to score the company. A hospital group wants to know whether a supplier will help it meet its own climate goals. An investor wants to know what could go wrong. Each of them sends a questionnaire: a spreadsheet, a Word file or a web portal full of questions, with its own deadline.

A drug company may answer more than ten of these a year, going by the one public average we found, from 2018.1 Each asks about emissions, water, waste, suppliers, human rights, ethics and staff. They ask much the same things, in different words and a different order. One says "Report your total Scope 1 and Scope 2 emissions." Another says "What was your operational carbon footprint last year?" A person has to see that those are one question.

Nobody holds all the answers. The emissions figures sit with the environment, health and safety (EHS) team. The human rights policy sits with procurement. The whistleblowing numbers sit with compliance. So one person, usually the ESG reporting lead, chases colleagues by email, copies last year's answer where it still looks right, gets approvals and sends the file.

The copying is where the trouble starts. Figures change: a plant is sold, an inventory is recalculated, an auditor corrects a number. Policies pass their review dates. Claims that were true two years ago stop being true. An old answer in an old spreadsheet carries none of that history, and it reads just as confidently as the day it was written.

One questionnaire, from a forwarded file to a submission

  1. A file arrivesA key account director forwards 18 questions from a group purchasing organization, in its own spreadsheet, due November 12.
  2. Each question is matched to a topic18 questions turn out to touch 18 topics in seven sections. Wording differs from every earlier form.
  3. Answers are found and checkedApproved wording is reused where it is still current. Each figure is compared with the latest inventory, and each claim with the latest evidence.
  4. Owners fill the gaps and approveTwo questions nobody has answered before go to the EHS director. A carbon-neutral question goes to counsel.
  5. The file goes back, and the record staysAnswers return in the requester's own format. If a figure later changes, whoever already holds it gets a correction.

Steps 2 to 4 are the subject of this guide. The people, companies and figures in this example are fictional.

Why a right answer goes stale, and three more surprises in ESG questionnaires

A correct answer has a shelf life

When a company sells a plant, the corporate standard of the Greenhouse Gas (GHG) Protocol, the accounting method nearly every emissions question assumes, says emissions for its base year, the year it measures progress against, shall be recalculated if the change is significant.2 An answer sent in March can be wrong by July with no mistake by anyone.

Customer pressure is growing fastest

In ERM's 2025 survey, customer demand was the top reason to engage with ESG ratings for 23% of companies, up from 7% in 2023.3 A hospital's form can carry weight in a tender.4

The burden has one old public measure

The one public figure we found is 18 workdays per response, from an April 2018 survey of more than 70 senior managers.1 We found no newer independent measure, so your own baseline will be stronger evidence.

The loudest green-claims law may not reach your form

The EU's ban on offset-based product claims applies only to business-to-consumer practices.5,6 A questionnaire to a hospital is business to business, and other rules reach it. Section 7 sorts them.

Four terms this guide relies on: Scope, restatement, assurance, library

Scope 1, 2 and 3

Scope 1 is emissions from what you burn yourself. Scope 2 is from the energy you buy. Scope 3 is everything else in your value chain, such as purchased materials.

Restatement

Publishing a corrected figure for a past year, after a sale, a purchase or an error found later.

Assurance

An independent firm's check of reported figures. Limited assurance is the lighter form: the firm says nothing came to its attention that suggests the figures are wrong.

Evidence library

One place for approved answers, each statement linked to the report, policy or data extract that supports it.

The full list of 14 terms is in the summary and glossary.

02 · Who sends them

Six kinds of requester behind a supplier sustainability questionnaire

In shortRating providers, a climate disclosure platform, customers, tenders, sector programs and investors all ask. They differ in what they do with the answer, and that sets how much care each one needs. A rating firm publishes a score. A hospital group may use the answer to choose a supplier. Customer demand is the part growing fastest.

The words overlap, so it helps to separate them. A rating provider turns data into a score it publishes or sells. A disclosure platform collects a standard response each year and scores it. A supplier assessment is a rating a customer asks you to take. A supplier sustainability questionnaire is a customer's own form, sometimes inside a tender, a formal contest for a contract. A sector program is an industry group's shared audit or published ranking. An investor survey feeds a fund manager's own view.

Who asksReal-world exampleThe formWhat your answer does
Disclosure platformCDP: over 22,000 companies disclosed in 20257Long annual web questionnaireBecomes a public score, and data others reuse
Supplier ratingEcoVadis: over 150,000 companies rated, by its own count8Questionnaire tailored to industry, size and country, with documentsA scorecard, and possibly a medal or badge
Investor-facing raterS&P Global ESG, one of the providers ERM's respondents rank highest for quality3,9An assessment, or a data review of what the rater already holdsA score investors read
Healthcare customerNHS England (England's National Health Service) supplier requirements4; hospital groups and purchasing organizationsTheir own spreadsheet, or a section of a tenderCan carry weight in a contract award
Sector programsPharmaceutical Supply Chain Initiative audits10; Access to Medicine Index, covering 20 companies11Audit, or a company data submissionFindings shared among members, or a published ranking
InvestorAsset managers' stewardship teamsWord or web surveyFeeds engagement and voting views

The names are examples of the kind of body, as described on their own pages on November 3, 2026. Nothing here says how any company has scored with any of them.

Customer demand tripled as the top reason to engage with ESG ratings, while investor demand slipped

Share of companies naming each as their top motivation, ERM Rate the Raters corporate surveys

20232025
Investor demand57%46%
Customer demand7%23%

Source 3 · 386 corporate sustainability professionals in 39 countries in 2025, fielded May to July 2025.

Show the numbers
20232025
Investor demand57%46%
Customer demand7%23%

Companies are also getting choosier. ERM reports that most now engage with three to five ratings, and that engagement with more than ten has fallen by more than half since 2023.3 Yet 84% plan to keep engaging, and 77% want rating methods aligned more closely with reporting standards.3 A company can drop a rating. It can rarely drop a customer's form: a key account director who wants the contract fills it in.

Pharma companies also ask each other. In July 2023 the leaders of seven global biopharmaceutical companies, members of a health systems task force, wrote to suppliers setting joint minimum climate and sustainability targets.12 In November 2025 chief procurement officers from the task force's members updated those targets, adding product carbon footprints or life cycle assessments for a supplier's top 10 products by 2028.13 A contract manufacturer or an ingredient maker can sit on both sides, answering its customers and sending forms to its own suppliers.

03 · The same question, reworded

Why 85 questionnaire questions can come down to 27 answers

In shortSustainability questionnaires overlap heavily, but rarely word for word. In the fictional case in this guide, six open forms hold 85 questions drawn from 27 topics. Climate appears in every form. The skill lies in seeing which question is being asked, then giving one answer to all of them.

Take the case this guide follows. Northwind Bio has six forms open. Their question counts run from 7 to 24, 85 in all, yet every one maps to one of 27 topics in seven sections. If each topic has one approved answer, the work of answering 85 questions shrinks to keeping 27 answers current, plus adapting each to the format and length a form asks for.

Climate is asked everywhere; the rest depends on who is asking

Questions per section in Northwind Bio's six open questionnaires

NoneOneTwoThree or more
Fernlake rating data reviewThornbeck HospitalsTerrasol ratingNational tenderMeridian purchasingQuillmere investorGovernance and strategyOneTwoOneOneTwoThree or moreClimate and energyThree or moreThree or moreThree or moreThree or moreThree or moreThree or moreWater and natureOneTwoNoneNoneTwoOneWaste and packagingNoneThree or moreOneOneTwoNoneSupply chain and human rightsNoneThree or moreThree or moreOneThree or moreTwoEthicsOneTwoTwoNoneOneTwoPeople, safety at work and accessOneThree or moreTwoNoneTwoThree or more

Fictional example from this guide · Counted from the fictional sample's questionnaires. Your own forms will differ.

Show the numbers
Fernlake rating data reviewThornbeck HospitalsTerrasol ratingNational tenderMeridian purchasingQuillmere investor
Governance and strategyOneTwoOneOneTwoThree or more
Climate and energyThree or moreThree or moreThree or moreThree or moreThree or moreThree or more
Water and natureOneTwoNoneNoneTwoOne
Waste and packagingNoneThree or moreOneOneTwoNone
Supply chain and human rightsNoneThree or moreThree or moreOneThree or moreTwo
EthicsOneTwoTwoNoneOneTwo
People, safety at work and accessOneThree or moreTwoNoneTwoThree or more

One emissions topic, as five requesters word it

Requester, fictionalHow it asksThe trap in the wording
Rating data review"Confirm: Scope 1 and 2 emissions, 2025."The rater shows you a value it already holds. Confirming by habit keeps an old number alive.
Hospital group"Report your total Scope 1 and Scope 2 (market-based) greenhouse gas emissions for the latest year, in tCO2e. Are they verified by a third party?"Two questions in one, and a method named. "Verified" has to be true on the day you answer.
Supplier ratingAsks for a total and an uploaded document.The document has to carry the same figure as the box.
National tenderAsks for your figures within a carbon reduction plan.The plan is public, so its figures can be compared with your other answers.
Investor"Absolute emissions, and the trend since your base year?"After a sale, the base year changes too.

The hospital wording is from the fictional sample. The others are written for this guide to show the pattern.

Format matters as much as words. A question may allow 1,000 characters, a yes or no plus a certificate, or a number per product. Numbering follows the requester's scheme: A.1 in one file, 2.1 in another, DP-02 in a rater's portal. Requesters generally expect their own structure back, so a good answer library holds meaning and evidence, and each form gets its own numbering and length on the way out.

04 · The rules and their dates

The 2026 rules behind ESG data requests, and where each one stands

Status as of November 3, 2026

In shortNo law says "answer this questionnaire." But several laws change who asks, what they may demand and what you may claim. Europe narrowed its reporting law sharply in 2026 and gave smaller suppliers a right to decline some requests. California's first emissions report is due November 10, 2026. The US federal climate rule never took effect and is being withdrawn.

Sustainability rules take effect one after another from 2026 to 2029
  1. Jul 2, 2026EU ESG ratings rules apply

    Rating providers need authorization from ESMA, the EU markets supervisor.

  2. Aug 12, 2026EU packaging regulation applies

    Packaging rules phase in from here.

  3. Sep 27, 2026EU consumer green-claims rules apply

    Bans offset-based product claims to consumers.

  4. Nov 10, 2026California first emissions report

    Scope 1 and 2, large US companies doing business there.

  5. Mar 19, 2027EU reporting law: national law due

    CSRD, the EU's sustainability reporting directive, with its narrower scope.

  6. Apr 2027NHS: global emissions

    Larger contracts, and new frameworks where proportionate.

  7. Dec 14, 2027EU forced labor regulation applies

    Bans products made with forced labor.

  8. Dec 31, 2028EU wastewater cost duty

    Medicine makers to fund treatment, under challenge.

  9. Jul 26, 2029EU due diligence applies

    Very large companies only.

Source 14,5,15,4,16,17,18,19,20

Show the numbers
WhenWhat
Jul 2, 2026EU ESG ratings rules apply
Aug 12, 2026EU packaging regulation applies
Sep 27, 2026EU consumer green-claims rules apply
Nov 10, 2026California first emissions report
Mar 19, 2027EU reporting law: national law due
Apr 2027NHS: global emissions
Dec 14, 2027EU forced labor regulation applies
Apr 2028NHS: product footprints
Dec 31, 2028EU wastewater cost duty
Jul 26, 2029EU due diligence applies
Rule or frameworkWhat it does to your questionnairesStatus on November 3, 2026
EU Corporate Sustainability Reporting Directive (CSRD), as cut by Directive (EU) 2026/470Limits mandatory reporting to companies over 1,000 employees and over EUR 450 million turnover. A company reporting under the law may not contractually require more than the EU's voluntary reporting standard from a supplier or other value-chain company of 1,000 or fewer employees, and must tell that company it may decline.14Published in the EU's Official Journal February 26, 2026; national law by March 19, 2027.14 The Commission lists delegated acts, its detailed rules, adopted July 3, 2026 on simplified standards and on the voluntary standard.21
EU Corporate Sustainability Due Diligence Directive (CSDDD), changed by the same directiveHuman rights and environmental due diligence, for companies over 5,000 employees and over EUR 1.5 billion worldwide turnover.14National law by July 26, 2028, applying from July 26, 2029.14
California SB 253US-based companies over $1 billion revenue doing business in California report Scope 1 and 2.17 Reports sent through the state regulator's intake platform will be made public, by one law firm's account, so other forms can test yours against them.22Regulation approved October 12, 2026; first report November 10, 2026; no third-party assurance this year. Scope 3 is previewed for later rulemaking.17 No ruling from the US Court of Appeals for the Ninth Circuit as of October 23.23
California SB 261Climate risk reports.Enforcement stayed by the Ninth Circuit pending appeal, as of October 23, 2026.23
US SEC climate rule (2024)Would have required climate disclosure in filings.Never took effect. Full rescission proposed May 29, 2026, comments closed August 3.24 We found no final vote on November 3, 2026.
EU ESG ratings regulationRegulates rating providers operating in the EU. Recital 12 of its preamble says a rated company should be able to ask for the dataset used and point out factual errors.15Applies since July 2, 2026. Existing providers had to notify ESMA by August 2 and apply for authorization or recognition by November 2, 2026; small providers notify by that same date.15,25
GHG ProtocolThe accounting method nearly every emissions question assumes. Chapter 5 of its corporate standard covers base year recalculation.2Current rules stand. Scope 2 consultation closed January 31, 2026. GHG Protocol's October 16, 2026 update slates a consolidated consultation for Q2 2027 and a joint GHG Protocol-ISO Corporate Standard for Q4 2028.26
Science Based Targets initiative (SBTi) Corporate Net-Zero Standard V2Sets what "science-based" and "net zero" targets mean, and gives carbon credits a role for ongoing emissions.27Published June 11, 2026.27 SBTi says V2 opens for use from the beginning of 2027, and Version 1 stays open for target submission until the end of 2027.28
This limit on what a reporting company may demand, the value-chain cap, covers requests made "for the purpose of sustainability reporting" under the directive, and a recital says it leaves alone information gathering "for any other purpose, such as for the reporting undertaking's risk management".14 On our reading, a hospital's tender or a customer's own supplier form asks for another purpose, so the cap gives no right to refuse it.

The right arrives through national law, due by March 19, 2027. A company of 1,000 or fewer employees should still know it exists, and a reporting company sending you a long form must say what goes beyond the voluntary standard.

05 · Why healthcare buyers ask

Why hospitals and the NHS now score medicine suppliers on carbon

In shortMedicines make up a large share of a health system's own footprint, so a buyer with a climate goal has to ask its suppliers. England's National Health Service (NHS) has set the clearest path: a net zero and social value weighting since 2022, a carbon reduction plan for contracts, global emissions reporting from April 2027, and product footprints planned from April 2028 with the method still open.

Health systems are responsible for 4 to 5% of global net emissions, or 2.4 gigatonnes of carbon dioxide equivalent, according to the 2022 release of the industry's own task force.29 The NHS has published a detailed breakdown. Its net zero report, first issued in 2020 and republished as statutory guidance in 2022, says medicines account for 25% of emissions within the NHS. Anesthetic gases are 2% and inhalers 3%, and the remaining 20% lies mainly in manufacturing and freight.30

Medicines are the largest named part of the NHS supply chain's emissions in its net zero plan

Share of emissions, as listed among supply chain interventions in NHS England's net zero report

Medicines and pharmaceuticals20%
Medical and non-medical equipment18%
Other procurement18%
Food and catering6%
Commissioned services outside the NHS4%

Source 30 · From the July 2022 file of the report. A wider footprint scope and an older base than any figure you will report; shown for scale.

Show the numbers
ItemValue
Medicines and pharmaceuticals20%
Medical and non-medical equipment18%
Other procurement18%
Food and catering6%
Commissioned services outside the NHS4%

What the NHS Net Zero Supplier Roadmap asks of a medicine supplier, and when

The NHS has moved from a tender weighting toward footprints for each product
  1. Apr 2022Net zero and social value

    At least a 10% weighting in NHS procurements, applied through the Evergreen assessment in NHS England medicines tenders.

  2. Apr 2023/24Carbon reduction plan

    New contracts above £5 million a year: UK Scope 1 and 2 and part of Scope 3.

  3. Apr 2024Plan for all new procurements

    Extended proportionately.

Source 4,16

Show the numbers
WhenWhat
Apr 2022Net zero and social value
Apr 2023/24Carbon reduction plan
Apr 2024Plan for all new procurements
Apr 2027All relevant global emissions
Apr 2028Product-level footprints

The April 2028 line needs the closest reading. The roadmap says the NHS "will work with suppliers and regulators to determine the scope and methodology" of product footprints.4 A test version of an NHS England market survey, from June 2026, asks suppliers of medicines, medical technology and digital products about collecting product-level emissions,31 and a law firm expects a market engagement exercise on the 2028 requirement.16 So a claim that the method is settled is premature.

Yet a questionnaire may already ask for a footprint per product, and the pharma task force's 2025 targets already ask for one on a supplier's top 10 products by 2028.13 A company holding only company-level figures has to say so plainly, then plan the calculation.

Outside England the picture is patchier. We found no public survey of how many US hospital groups or purchasing organizations put sustainability questions in supplier contracts, so we give no figure. Ask your own account teams how many they received last year. That count will tell you more than any market estimate.

06 · One emissions figure, worked through

How one company's 2025 emissions can truthfully read three ways, and which one to give

In shortScope 2 can be counted two ways, and a figure can be preliminary or assured. Add a plant sale, which forces the base year to be recalculated, and one company has several defensible-looking numbers for one year. A questionnaire answer has to name the method and the status, and it has to be the same everywhere.

Follow the fictional Northwind Bio's 2025 numbers. Scope 1, what it burns itself, is 21,480 tonnes of carbon dioxide equivalent (tCO2e). Scope 2, its purchased energy, depends on the method. Market-based counts the electricity contracts the company bought, and gives 37,440. Location-based uses the average mix of the local grid, and gives 49,800.

The sums, fictional
21,480 + 37,440 = 58,920 tCO2e, Scope 1 and 2, market-based, assured
21,480 + 49,800 = 71,280 tCO2e, Scope 1 and 2, location-based
61,400 − 58,920 = 2,480 tCO2e, the gap to the preliminary figure sent in March
1 − (58,920 ÷ 89,270) = 34%, the reduction since the restated 2021 base year
One company, one year, three figures that could each land in a questionnaire

Northwind Bio's 2025 Scope 1 and 2 emissions, tCO2e

Location-based Scope 2a different method71,280
Preliminary, sent in Marchsuperseded61,400
Assured, market-basedthe one to give when market-based is asked58,920

Fictional example from this guide

Show the numbers
ItemValue
Location-based Scope 271,280
Preliminary, sent in March61,400
Assured, market-based58,920

What a plant sale does to a base year

A base year is the year a company measures its progress against. The GHG Protocol treats a sale as a structural change: it moves emissions to another company's books without any change in the atmosphere. So "base year emissions shall be retroactively recalculated" when the change would otherwise compromise consistency, and the company sets and discloses the significance threshold that triggers this.2 The standard names no number for significant, though it notes that one program used 10% of base year emissions.2

That is why a restatement touches more than one cell. Northwind Bio's sale changed its 2021 base to 89,270 tCO2e and its 2024 figure to 64,930. Every form that reports a trend or a percentage since 2021 is affected, along with any target stated against that base.

The old figure went out before the restatement, and nothing told the customer
  1. Feb 2026Plant 6 sold

    A structural change in the fictional inventory.

  2. Mar 20, 2026Answer sent to Merrow Health

    61,400 tCO2e, described as verified.

  3. May 29, 2026Limited assurance statement

    Covers Scope 1 of 21,480 and Scope 2 of 37,440.

  4. Jun 2026Inventory restated, report published

    58,920 tCO2e, page 22 of the report.

  5. Oct 7, 2026Still in two open forms

    And with one customer who has no way of knowing.

Fictional example from this guide

Show the numbers
WhenWhat
Feb 2026Plant 6 sold
Mar 20, 2026Answer sent to Merrow Health
May 29, 2026Limited assurance statement
Jun 2026Inventory restated, report published
Oct 7, 2026Still in two open forms

The questions to ask of any emissions answer before it goes

Which method?

Market-based or location-based, or both. Say which. A form that asks for one and gets the other has received a wrong answer, even when each number is correct.

Which status?

Preliminary, reported or assured, and by what level of assurance. Limited and reasonable assurance are different levels, so say which. The EU reporting law works with limited assurance, and its Commission standards are due by July 1, 2027.14

Which boundary and year?

Calendar year, reporting entities, and whether the sold plant is in or out.

Who else has it?

Every form and every customer that holds the old value. Nobody can correct an answer they cannot find.

07 · Carbon-neutral claims

Can you still answer "carbon neutral" on a questionnaire? Which greenwashing rule reaches it

Status as of November 3, 2026

In shortA claim of being carbon neutral through offsets has become risky almost everywhere, but the rule depends on the audience. The EU's new ban covers products marketed to consumers. A form going to a hospital is business to business, where US guides and general misleading-advertising law apply. In every case the claim has to be true today, and a two-year-old answer may no longer be.

Greenwashing means making something look better for the environment than the evidence supports. Carbon neutrality is the classic case, because the phrase can mean two very different things: the emissions were avoided, or they were paid for elsewhere through offsets, credits for reductions made outside the company.

Germany's Federal Court of Justice addressed that ambiguity on June 27, 2024 (I ZR 98/23). A confectionery maker's advertisement in a food-trade newspaper said it produced "climate neutral". The court held this misleading unless the advertisement itself explained which meaning applied, because reduction and compensation are not equivalent. A link or QR code elsewhere was not enough.32 The readers were the trade, which puts the case close to a supplier's position, though it rests on German unfair competition law.

The new EU ban targets consumer products; a supplier questionnaire falls under older, wider rules

Our reading of how directly each text reaches an offset-based claim, by where the claim is made

Not aimed herePossiblyReaches it in partApplies directly
Consumer ad for a productBusiness-to-business marketingAnswer in a customer questionnaireCompany-level statement in a reportEU Directive 2024/825Applies directlyPossiblyPossiblyNot aimed hereUS FTC Green GuidesApplies directlyApplies directlyReaches it in partPossiblyUK Green Claims CodeApplies directlyReaches it in partReaches it in partPossiblyGeneral law on misleading statements and contract termsApplies directlyApplies directlyApplies directlyReaches it in part

Our reading of the sources 5,6,33,34 · Not legal advice. Take a questionnaire answer to your own counsel, because tender terms and national law can change the result.

Show the numbers
Consumer ad for a productBusiness-to-business marketingAnswer in a customer questionnaireCompany-level statement in a report
EU Directive 2024/825Applies directlyPossiblyPossiblyNot aimed here
US FTC Green GuidesApplies directlyApplies directlyReaches it in partPossibly
UK Green Claims CodeApplies directlyReaches it in partReaches it in partPossibly
General law on misleading statements and contract termsApplies directlyApplies directlyApplies directlyReaches it in part
TextWhat it saysStatus
Directive (EU) 2024/825Bans "claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions". Companies may still advertise investment in carbon credit projects if the information is not misleading.5 It applies only to business-to-consumer practices, though member states may extend protection to business relations.5,6Applies from September 27, 2026. Eight member states had notified no national measure, the law firm Mayer Brown reported on October 27, 2026.6
FTC Green Guides, 16 CFR Part 260"These guides also apply to business-to-business transactions."33 Sellers of offsets need competent and reliable methods, and may not misrepresent when reductions occur.33 They are guidance on what the FTC treats as deceptive.Last revised in 2012. The newest review step on the FTC's page is a May 2023 workshop.35
UK Green Claims CodeSix principles, including "claims must be substantiated". It "also applies (to a more limited extent) to businesses marketing to other businesses", because the business rules cover misleading advertising and comparisons and leave out other misleading practices.34Published September 20, 2021. The page still cites the 2008 consumer regulations; ask counsel what later UK law has changed.34
EU Green Claims Directive (proposal)Would have required prior verification of claims.Not law. The Commission said in June 2025 that it meant to withdraw it, then said on July 1, 2025 that a full withdrawal was not planned.36 Parliament's file, read November 3, 2026, still shows it awaiting the Council's first reading position.37
SBTi Net-Zero Standard V2Recognizes companies for how they address ongoing emissions, including high-quality credits.27 SBTi calls this a complement to cutting your own footprint.28 On our reading it gives no neutrality claim.Published June 11, 2026.27

How an honest carbon-neutral answer reads after the offsets end

In the fictional case, the form asks "Are your operations or products carbon neutral? If yes, provide the certification." The 2024 answer said yes. The company stopped buying credits on January 1, 2026, and its transition plan says it does not use the phrase. A sound answer is short and specific: no, what the company does instead, what the reduction is, and where each statement comes from.

Old answer, fictional
Said
Yes, carbon neutral since 2022, through offsets
Approved
Nov 2024
Evidence now
Contradicted by the 2026 plan
Current answer, fictional
Says
No. No credits for operations since January 2026
Instead
34% below 2021, a 42% target for 2030
Evidence now
Three cited passages
08 · Policies, water and suppliers

Beyond carbon: the human rights, wastewater and supplier evidence drug makers get asked for

Status as of November 3, 2026

In shortMany answers rest on documents, and documents age quietly. A policy past its review date can sit attached to three forms with nobody noticing. Drug makers face subject-specific questions too: wastewater (effluent) from sites that make active ingredients, supply chain audits, packaging and access to medicines. Each has a rule or program behind it, with its own date.

A questionnaire asking you to "attach the current version" of a policy is asking two things: that the policy exists, and that it is current. In the fictional case, a human rights policy approved in September 2023 says it is reviewed at least every three years. So its review fell due in September 2026, and three open questionnaires cite it. No figure is wrong, and the answer is still stale.

TopicWhat a form typically asksThe rule or program behind itStatus
Wastewater (effluent) from active-ingredient sitesResults per site against discharge limits. One missing site makes the whole answer incomplete.Pharmaceutical supply chain programs and customer forms. Directive (EU) 2024/3019 also makes producers of medicines and cosmetics fund at least 80% of extra wastewater treatment costs.20Duty by December 31, 2028; national law by July 31, 2027.20 The EU General Court dismissed 16 challenges on standing, the right to bring a case, in February 2026, appeals pending; an Irish court referred questions on May 20, 2026.38 Parliament's non-binding resolution of June 18, 2026 asks for a pause.39 We found no change to the text.
Human rights and forced laborA policy, a modern slavery statement, a risk assessment of suppliers.UK Modern Slavery Act section 54 requires certain organizations to produce a statement each year.40 Regulation (EU) 2024/3015 will ban products made with forced labor.19UK guidance page updated December 1, 2025.40 EU regulation applies from December 14, 2027.19
Supplier auditsHow many assessed, how many audited on site, how many on corrective plans.The Pharmaceutical Supply Chain Initiative shares audits among its members, with 86 members listed on its site by our count.10Read November 3, 2026.10
PackagingRecyclable share by weight, plans to replace materials such as PVC blisters.Regulation (EU) 2025/40 on packaging.18Applies from August 12, 2026, with requirements phasing in later.18 Check which apply to medicinal packaging.
Access to medicinesPrograms, countries reached, pricing approach.The Access to Medicine Index ranks 20 large research-based companies.11The 2024 edition is the newest on the page we read.11
More than half the sample's topics rest on a figure that changes every year, the rest on documents that age

What the 27 topics in the sample rest on

A figure that changes each yearA policy or plan with a review dateA published description
27 topics1575

Fictional example from this guide · Our classification of the fictional sample's topics, including its two new questions. Classify yours the same way: it tells you what to watch.

Show the numbers
A figure that changes each yearA policy or plan with a review dateA published description
27 topics1575
A partial answer can read as a full one. If a form asks for results from "each site that manufactures active ingredients" and you have four such sites, results for three do not answer it. Say what is missing and when it will arrive. A reviewer who finds the gap on their own will doubt the rest of the form.
09 · Rating data reviews

How an ESG rating data review works, and how EU law lets you check the dataset

Status as of November 3, 2026

In shortRating firms gather data on your company whether you answer or not, then often let you check it. Since July 2, 2026, EU rules say a rated company should be able to see the data used and flag factual errors. That covers facts and gives no say over the method or the score. A data review is also the place an old figure most easily survives.

A data review looks easy: the rater shows what it holds and asks you to confirm it. It takes less work than a full questionnaire, so it gets less attention. In the fictional case, the rater still holds 61,400 tCO2e, and confirming by habit would keep that number alive in a product investors read.

Regulation (EU) 2024/3005 now gives this a legal footing in the EU. Recital 12, part of the law's explanatory preamble, says rated companies should be able to verify the data used and highlight factual errors, and to get the dataset on request, as "a pure fact-checking tool". They should "under no circumstances be able to influence in any manner the rating methodologies or rating outcome".15

Article 19 requires a complaints process, covering "the sources of data used for an individual ESG rating, factual errors and mistakes".15 Recital 42 notes ratings are also used "in the procurement and supply chain context".15 Private ratings not meant for publication or distribution fall outside the regulation.15

One disclosure cycle: the CDP dates a company planned around in 2026

A scored climate response has a fixed window, and the 2026 one has closed
  1. Week of Apr 20, 2026Questionnaires released

    With guidance.

  2. Week of Apr 27, 2026Scoring method published

  3. Week of Jun 15, 2026Response window opens

  4. Sep 16, 2026Scoring deadline

    A limited number of extensions had to be requested by September 29.

  5. Week of Oct 26, 2026Final disclosure deadline

    Not eligible for scoring.

Source 7,41,42

Show the numbers
WhenWhat
Week of Apr 20, 2026Questionnaires released
Week of Apr 27, 2026Scoring method published
Week of Jun 15, 2026Response window opens
Sep 16, 2026Scoring deadline
Week of Oct 26, 2026Final disclosure deadline

A cycle like this also shows why status matters. A response submitted in September fixes a figure for months. Your restatement in the following June then sits beside last year's public data, and customers may ask why the numbers differ. A short note explaining the recalculation, kept with your evidence, will answer most of them.

This guide names real rating bodies and states no scores. Nothing here says or implies that any real company holds any rating. Rating methods change often, so read each provider's current method before relying on anything said about it here.
10 · The common errors

The eight mistakes that show up in sustainability questionnaire answers, and why each happens

In shortNo regulator or study publishes an error rate for questionnaire answers. What follows comes from the rules and the mechanics of the work. Most errors have one cause: a copied answer that lost its date, its method or its source along the way. The hardest to fix are the ones already in someone else's hands.

ErrorWhy it happensHow to catch it
Superseded figureA restatement changes the report. Old spreadsheets keep the old value.Compare each figure with one register of current values.
Mixed methodMarket-based in one form and location-based in another, unlabeled.Store the method beside the value.
"Verified" too earlyWording carried from last year, before this year's assurance exists.Check the assurance date against the answer date.
Expired claimA carbon-neutral answer reused after the offsets ended.List risky wording and send any match to counsel.
Stale policyNobody watches review dates in attached documents.Hold each document's review date and flag every answer that cites it.
Partial evidence shown as fullResults for three sites of four.Read the question's scope, then count.
Invented answer to a new questionA deadline, plus a form that will not submit with a blank.Route it to an owner and say what is missing.
No record of who has whatSubmissions live in email and account folders.Log each figure sent, to whom and when.
Expired claims and superseded figures are the errors to check every time
Consequence once it is outside →
Named approver
Check every time
Note it
Fix in passing
Expired claimVerified too earlySuperseded figureInvented answerStale policyPartial evidenceMixed method
How easily it happens in everyday copying →

Our reading of the sources 5,2,33 · Our judgment. Measure your own by sampling past answers (Part C).

Show the numbers
ItemHow easily it happens in everyday copying (0–1)Consequence once it is outside (0–1)
Expired claim0.600.80
Verified too early0.120.71
Superseded figure0.750.63
Invented answer0.120.54
Stale policy0.750.30
Partial evidence0.120.25
Mixed method0.600.14

What makes a wrong number hard to take back

A figure in a customer's file can be copied into that customer's own Scope 3 calculation. A figure in a rater's database can be sold on. A correction needs someone to find everyone who holds the old value, explain the change without alarm, and leave a record of having done so. When there is no list of recipients, the usual result is no correction at all.

11 · The published numbers

What ESG questionnaire fatigue costs in published numbers, and what nobody has measured

In shortThe one public measure we found is eight years old: 18 workdays a response and more than ten requests a year, from April 2018, or about 180 workdays. Recent surveys describe who rates and why, with no measure of hours. We found no credible public figure for the market for this software or the cost of a wrong answer. Measure your own.

18 workdays

on average to submit a response to a single request, according to more than 70 senior managers.1

The Conference Board, April 2018
10+ a year

requests companies respond to on average, in the same survey.1

The Conference Board, April 2018
180 workdays

18 workdays × 10 requests. The survey brief does not say whether those are full days of effort. If they are, the total comes to more than half a person-year.

Our arithmetic on 2018 figures
Most companies will keep answering, even as nearly half doubt ratings will stay as relevant
84 in 100

corporate sustainability professionals plan to keep engaging with ESG ratings; 46% believe their relevance will decline over time

Source 3

Show the numbers
MeasureValue
corporate sustainability professionals plan to keep engaging with ESG ratings; 46% believe their relevance will decline over time84 of 100

How far to trust each number, and what to measure instead

NumberWhat it isIts limit
18 workdaysAverage time to submit one response, in a Conference Board brief of April 20, 2018.1Self-reported, from more than 70 managers, and older than the rise in customer demand ERM reports.3 The brief does not say whether these are elapsed days or days of effort. The full survey is for members.43 A 7-point data review is not a 300-question disclosure.
3 to 5 ratingsWhat most companies now engage, per ERM's 2025 survey of 386 professionals.3Counts ratings. It leaves out customer forms, tenders and investor surveys.
22,000+ and 150,000+Companies disclosing through CDP in 2025, and rated by EcoVadis, each on its own page.7,8Each provider's own count. They overlap, and neither measures effort.
Market sizeNo credible public figure for ESG questionnaire software.Vendor estimates exist, with no method shown. We leave them out.
Cost of a wrong answerNo public figure.Part C lists what to count in your own company.
12 · What AI changes

Can AI answer an ESG questionnaire? What it checks well, and where a person has to decide

Status as of November 3, 2026

In shortAI suits the parts you can check: reading a form, matching a question to a topic, reusing approved text and comparing figures. It cannot decide whether a claim is fair, or fill a true gap. No drug-regulatory AI rule was written for this work, so ordinary care applies: a source for each statement, a named approver, and nothing sent unapproved.

Automate what a reader can check against a passage; keep judgment on claims with people
Consequence of a wrong answer →
Keep with people
Person approves
Leave as is
Automate first
Judge a claimCompare figuresNew questionsDraft answersMatch topicsRead the form
How easily a person can check the output →

Our reading of the sources 44

Show the numbers
ItemHow easily a person can check the output (0–1)Consequence of a wrong answer (0–1)
Judge a claim0.120.80
Compare figures0.750.70
New questions0.120.62
Draft answers0.720.53
Match topics0.720.30
Read the form0.750.14

A warning from a neighboring field: researchers tested legal research tools built to answer from retrieved documents, and found them hallucinating 17% to 33% of the time, meaning an answer that was incorrect or cited a source that did not support it. Those tools were tested in 2024 and work on law, so the rate does not transfer. The lesson does: a source attached to an answer can still fail to support it.44 Someone, or something, has to check that the passage says what the sentence says.

TextDoes it reach this work?Status
EU AI ActOn our reading, drafting a sustainability answer for a person to approve is outside the high-risk list. Check the system as you use it.Regulation (EU) 2026/1744 moved high-risk dates: Annex III to December 2, 2027, Annex I products to August 2, 2028.45
FDA draft on AI for regulatory decisionsCovers AI that produces information to support regulatory decisions on drugs.46 A questionnaire to a customer falls outside that scope.Draft, January 2025.46
Draft EU GMP Annex 22Written for AI in medicine manufacturing, under good manufacturing practice (GMP). Says generative AI and large language models "should not be used in critical GMP applications".47 A sustainability answer and its emissions data fall outside GMP work.A draft. EudraLex Volume 4 lists no Annex 22 on November 3, 2026.48
FDA Computer Software AssuranceScope is production and quality system software for medical devices.49 It has no bearing on this work.Final guidance, February 2026.49
ALCOA and data integrityThe GXP guidance from MHRA, the UK medicines regulator, explains ALCOA: data should be attributable, legible, contemporaneous, original and accurate.50 No rule requires it for a sustainability answer. It is still a useful habit: who wrote this, when, and from what.MHRA guidance, current on its page.50
No software is "certified" for GxP or Part 11. GxP is the family of good-practice quality rules for regulated laboratory, clinical, manufacturing and distribution work, and Part 11 is FDA's rule on electronic records and signatures. They apply to how a company uses a system, and this work usually sits outside them anyway. Ask a vendor which controls it provides, such as named approvers and an audit trail. Treat any claim of being "ESG compliant" with care: nobody grants that status.
13 · How teams do it today

How ESG reporting teams answer questionnaires today: roles, hand-offs and where the 2018 survey's 18 workdays go

In shortAn ESG reporting lead coordinates from spreadsheets. EHS, procurement, compliance, HR, legal and account teams each hold a piece. By our estimate, most of the time goes to finding old answers and chasing colleagues for the same figures. Teams use spreadsheets, request-for-proposal (RFP) answer tools, ESG reporting suites or consultants, and each leaves the same gap: nothing links an answer to the evidence as that evidence changes.

Who touches a sustainability questionnaire inside a drug company

ESG reporting lead

Runs the season, owns governance and climate answers, signs off each submission.

EHS director

Holds the greenhouse gas inventory, water and waste data. Gets asked for the same figures all year.

Procurement sustainability lead

Owns the supplier code, audits and human rights answers.

Ethics and compliance, HR, access

Own anti-bribery and speak-up numbers, workplace figures, and access to medicines.

Counsel for environmental claims

Gives a second approval on public claims, when anyone remembers to ask.

Key account director

Receives hospital and purchasing forms, and sends them back.

Six steps, each with its hand-off, stand between a forwarded file and a submission
  1. 1File arrives

    A customer's form lands in an inbox.

    Key account directorDay 0
  2. 2Read and split

    Questions sorted by who might know.

    ESG reporting leadDays 1–2
  3. 3Find old answers

    Last year's file, a shared drive, a colleague's memory.

    ESG reporting leadDays 3–6
  4. 4Chase owners

    Email to EHS, procurement, HR, legal, with reminders.

    Section ownersDays 7–12
  5. 5Check and approve

    Figures against the report; legal on claims.

    Owners and counselDays 13–16
  6. 6Write back and send

    Answers typed into their format.

    Key account directorDays 17–18

Illustrative · replace with your own numbers · Illustrative sequence inside the 18-workday average published in April 2018.

Show the numbers
StepWhat happensWhoTime
File arrivesA customer's form lands in an inbox.Key account directorDay 0
Read and splitQuestions sorted by who might know.ESG reporting leadDays 1–2
Find old answersLast year's file, a shared drive, a colleague's memory.ESG reporting leadDays 3–6
Chase ownersEmail to EHS, procurement, HR, legal, with reminders.Section ownersDays 7–12
Check and approveFigures against the report; legal on claims.Owners and counselDays 13–16
Write back and sendAnswers typed into their format.Key account directorDays 17–18
Chasing colleagues and finding old answers take more than half of the 18 workdays, on our estimate

Our estimated split of the 2018 survey's 18 workdays. We found no measured one.

Read and mapFind answers and evidenceChase ownersCheck and approveWrite back and send
One questionnaire2464.5

Illustrative · replace with your own numbers · Replace with your own timing of two or three recent forms.

Show the numbers
Read and mapFind answers and evidenceChase ownersCheck and approveWrite back and send
One questionnaire2464.51.5

Spreadsheets, answer tools, reporting suites, consultants: four ways teams run the season

The wayGood atWhere it falls short
Spreadsheets and emailCheap, familiar, flexibleNo link to evidence, no record of who holds which value
RFP answer librariesFinding and reusing past textText reuse with no check of figures against current data, or of claims
ESG reporting suitesCollecting data and producing the annual reportBuilt around one annual report, with each outside form and format handled separately
ConsultantsScoring advice, surge capacityKnowledge leaves with them, and the cost repeats each year
Part B · See it working

Botminds ESG Questionnaire Response on one season at a fictional drug maker

Part A described the work without naming a product. This part shows how Botminds does it, at a fictional mid-size drug company with six open questionnaires. Every company, person, document, date and figure in the screens is sample data, and no rating shown or implied belongs to a real company.

14 · One season, start to finish

From a new purchasing-group file to a correction note: Northwind Bio on October 7

In shortThis is the example from the top of the page, inside the product. Priya Ranvelle, the ESG reporting lead, sees 27 topics against six questionnaires on one matrix, fills a new 18-question file from the library, puts the assured emissions figure into every open form, and sends a drafted correction to the customer who holds the old one.

1

Every topic in every open questionnaire, on one screen

Priya's home screen is a coverage matrix: 27 topics down, six open questionnaires across. A cell can be approved, drafted and waiting for review, flagged, with its owner, or a gap. A second column shows how fresh the library's answer is, and how many questionnaires ask it.

Scope 1 and 2 emissions is amber in two columns. The Fernlake ESG Ratings data review and the Thornbeck Hospitals questionnaire both carry 61,400 tCO2e. The panel on the right shows the library answer: 58,920 tCO2e, with three numbered sources.

The coverage matrix. Each cell is one answer in one questionnaire. The top banner announces the new file, read and mapped before anyone opens it.
2

One click fills 15 of the 18 answers

The Meridian Group Purchasing file arrived yesterday from Sam Patel, the key account director. Priya clicks "Fill from the library." Twelve approved answers are reused and three more are drafted from cited passages, so 15 of 18, or 83%, are answered. Those numbers come from the sample. The solution's design target for a new file is 80% or more.

The other three go to people: the carbon-neutral question to Grace Liu, the claims counsel, and two questions the library has never answered to Omar Haddad, the EHS director.

Filled from the library. The new column turns from dashed outlines to approved, drafted and assigned cells, and the banner counts the result.
3

A new question goes to an owner, with no invented answer

The form asks for a product carbon footprint for each product supplied. The library holds company-level emissions only, so the cell says so and routes the question to Omar. Once he writes and approves an answer, the next form that asks it fills by itself.

A new question routed. The reason is stated, along with the answer format the requester wants. NHS England's own product-level method is still to be set (section 5).
4

Update everywhere: the assured figure replaces the old one

Priya owns Climate and energy, so she alone is offered the update. The library says 58,920 tCO2e for 2025: Scope 1 of 21,480 and market-based Scope 2 of 37,440, with limited assurance from Corrigan Vale Assurance LLP, restated in June 2026 after the sale of a plant. One click writes it into the Fernlake and Thornbeck answers, and both now read "Updated from the library today." The change goes on the audit trail with every questionnaire it touched.

Updated everywhere. Open forms take the new value. The ringed entry is a questionnaire already submitted, which stays as sent.
5

The customer who already has the old number gets a note

Merrow Health received 61,400 in March. A submitted answer is never changed silently, so a correction note is drafted from the facts register, the list of current approved figures: the plant sale, the recalculation, the assured figure and page 22 of the report. Sam Patel sends it, as the account lead.

The correction note. Drafted for the account lead to read and send. The old answer also said "verified", and the assurance statement is dated May 29, after that answer. A careful team would tell the customer that too.
Fifteen of the new file's 18 questions were answered before anyone chased a colleague

The Meridian Group Purchasing file in the sample

Questions read18
Answered from the library15
Reused approved answers12

Fictional example from this guide · The other three went to people: one claim to counsel, two new questions to the EHS director.

Show the numbers
StageCount
Questions read18
Answered from the library15
Reused approved answers12
15 · Every screen

The claim check, the facts register, the owners view and the dashboard, on screen

In shortBehind the matrix sit one workspace per questionnaire, a library of documents and a register of current figures, an owners view, an export with its approval log, and a dashboard. Each screen below shows one control that a spreadsheet lacks.

A figure flagged. The topic panel before the update: what the library holds, who asks, which forms disagree, and the button only the owner gets.
One answer, its sources. The requester's own question number and length limit, each numbered citation opened at its passage, and the steps that built the answer. The inventory, the assurance statement and the report are all sample documents.
A claim stopped. A 2024 answer reused after the offsets ended, with approved wording offered in its place. The screen's "Green-claims rules require any such claim to be current and substantiated" is the sample's summary. The real position varies by audience and country, as section 7 explains.
A gap in the evidence. The question asks for every active-ingredient site. Results exist for three of four, so the answer stays flagged until the owner responds.
A submitted answer stays as sent. Read only, with its source marked as a superseded figure, and an offer to draft a correction.
A policy past its review date. Three open forms cite it. One request goes to Lena Ortiz, and when the reviewed policy lands, each citing answer is checked again.
Section owners. Each owner approves only their own section, with the evidence attached. Public environmental claims also need counsel.
Export, with approvals. A review copy is available at any time. The submission file becomes available once every answer is approved.
All requests. Every rating, customer and investor form, with the requester's due date, stage and lead.
The evidence library. Each document has an owner, a count of the answers citing it, and a freshness status.
The facts register. One value per metric, its status (assured or reported) and how many requests ask it.
Your own rules. Claim wording that needs a second approval, how long an approved answer can be reused, and how fast owners should respond.
The dashboard. Sample data for one year. The 18-workday baseline is the Conference Board's April 2018 figure. Reuse appears twice: 54% is the average per request, and 58% is the share of all answers submitted.
What the checks caught. Figures, claims, documents and gaps found before anything was sent, with each owner's median turnaround.
Workdays per request fall as the library fills, and a large rating form still takes longer

Workdays for eight submitted requests in the sample's year, against the April 2018 survey's average of 18 workdays

16Feb
12Mar
9May
7Jul
8Aug A
21Aug B
14Sep A
6Sep B

Fictional example from this guide · Sample data. Average 11.6 workdays, so about 51 workdays saved against the 2018 baseline of 18. August B is the corporate assessment.

Show the numbers
PeriodValue
Feb16
Mar12
May9
Jul7
Aug A8
Aug B21
Sep A14
Sep B6
Nearly three in five submitted answers reused approved wording
Reused approved answers: 58Drafted from evidence: 31Written by the owner: 11
58%reused
  • Reused approved answers58
  • Drafted from evidence31
  • Written by the owner11

Fictional example from this guide

Show the numbers
PartValue
Reused approved answers58
Drafted from evidence31
Written by the owner11
Gaps and wrong figures made up most of the 31 issues caught before submission

Year to date, in the sample.

Gaps routed to owners11
Figures that disagreed with the register9
Documents past their review date7
Unsupported environmental claims4

Fictional example from this guide

Show the numbers
ItemValue
Gaps routed to owners11
Figures that disagreed with the register9
Documents past their review date7
Unsupported environmental claims4
16 · Who drafts and who signs

Six agents read and check each sustainability answer; section owners approve it

In shortSix agents read each form, match each question, draft with citations, check figures and claims, route work and write the file back. They never approve anything. Each section owner approves their answers, counsel gives a second approval on public environmental claims, the ESG reporting lead signs off, and only approved answers export.

What each of the six questionnaire agents does, and will not do

Questionnaire reader

Finds every question, section, answer format, length limit and attachment in Excel, Word, PDF or a portal export, and keeps each original reference.

Never changes the requester's wording or numbering.

Evidence matcher

Maps each question to the topic it asks about and to the approved answer and passages, preferring the newest assured source.

Never matches an answer older than your reuse window without re-approval.

Answer drafter

Reuses the approved answer when it fits, or drafts from evidence in the requester's format and length, with a numbered citation for each statement.

Never states a figure that has no source passage.

Consistency and claim checker

Compares each figure with the facts register and each claim with your claim rules, flags documents past review, and proposes the fix with both sources side by side.

Never lets a superseded figure or a blocked claim through silently.

Owner router

Sends each section, gap or flagged claim to its owner with the evidence, and a due date two working days before the requester's.

Never approves on an owner's behalf.

Export composer

Writes approved answers back into the requester's own file or portal format, with the evidence asked for and a record of who approved each answer.

Never exports an unapproved answer.

The people answering Northwind Bio's questionnaires, and who signs what

Fictional, from the sample data
PR

Priya Ranvelle · ESG reporting lead

Owns governance and climate answers and signs off each submission.

"I want to answer the emissions question once, and stop answering it fourteen times."
OH

Omar Haddad · EHS director

Data steward for water, waste and the greenhouse gas inventory.

"Send me the gap. You can keep the spreadsheet."
LO

Lena Ortiz · procurement sustainability lead

Owns the supplier code, audits and human rights answers.

"Tell me which answers break when the policy changes."
GL

Grace Liu · counsel, environmental claims

Gives the second approval on any public environmental claim.

"Nothing says carbon neutral unless I have seen the evidence."
SP

Sam Patel · key account director

Receives hospital and purchasing forms, submits the files and sends correction notes.

"Customers want it in their own spreadsheet, by Friday."

Questionnaire controls that make every answer defensible

Maker and checker

Agents draft. The section owner approves, counsel approves public claims, and the ESG lead signs off. The person who owns a topic is the only one offered "update everywhere" for it.

One source for each statement

Every factual sentence links to a passage in a report, policy, data extract or assurance statement. A figure that differs from the register is flagged with both sources.

A full audit trail

Each step, upload, approval, rule change and update is recorded with who, what and when, including every questionnaire it touched. Submitted answers change only through a correction.

Roles and enterprise security

Named roles per section and single sign-on through your identity provider. SOC 2 Type II audited, with information security managed to ISO 27001. Your data is not used to train models.

17 · What goes in, what comes out

From rating portals and customer spreadsheets to a cited file with its approval log

In shortIn go the questionnaires and everything your answers already rest on. Out comes a coverage matrix, cited drafts in each requester's own format, assigned gaps, correction notes and a submission file with its approval log. It connects to the systems your sustainability data already lives in, across your whole portfolio of sites and requesters.

Questionnaires

  • Rating provider and disclosure portal exports
  • Customer spreadsheets and tender sections
  • Investor surveys, in Word or PDF
  • Files forwarded to an ESG mailbox

Your evidence

  • The sustainability report and its GRI index
  • Greenhouse gas inventory and assurance statement
  • Policies and statements, with review dates
  • EHS and HR data extracts
  • Past responses
Agents read, match, draft and check Every question, every requester, under your owners and your claim rules
Owners approve each answer
Every statement cited to its passage

Outputs

  • A coverage matrix of each topic in each questionnaire
  • Draft answers with citations, in the requester's format
  • Gaps and flagged claims assigned to owners
  • Correction notes for submitted answers
  • A submission file with its approval log

What changes for the team

  • Owners receive the gap, with the evidence, and no spreadsheet
  • A restatement reaches each open form in one step
  • You can list who holds which figure

It connects to the kinds of system you already run: your document management system or policy library, EHS data system, HR data, email and identity provider. Answers go back as files in the requester's own format, or as a portal export.

To be measured on your own forms: about half the time per questionnaire (the 2018 survey's 18 workdays to about 9, our estimate, which is about 90 workdays a year at 10 requests) and a design target of 80% or more of a new file filled from the library on arrival. The sample shows 83% and 31 catches. None of these is a measured customer result.

Part C · Are you ready to automate?

Deciding whether to automate your sustainability questionnaires: costs, return, readiness, vendors and a pilot

Written to you, the person who has to decide. Start with your own numbers, score your readiness honestly, and hold any vendor, including us, to the questions below.

18 · What the season costs you

What a questionnaire season and a wrong answer cost you, and how to find your own number in a week

In shortThe one published figure, from a 2018 survey, works out to about 180 workdays a year. A wrong figure has no published price. It may mean a correction to a customer, a data dispute with a rater, or a lost tender weighting. You can measure the part that matters most in a week, from your last five forms.

180 workdays

a year at 18 workdays per response and 10 requests, the Conference Board's averages.1

Survey of 2018; your count is likely different
10%

the minimum net zero and social value weighting in NHS procurements, per NHS England's June 2026 roadmap.4

A real tender stake, in one market
Nov 10, 2026

California's first Scope 1 and 2 report, for US-based companies over $1 billion revenue doing business there. Reports sent through the state regulator's intake platform will be made public, so a figure can sit beside your forms.17,22

Status as of October 19, 2026
Most of the time saved comes from finding, mapping and chasing, and approvals barely move

Workdays for one questionnaire, our split of the 2018 survey's 18 workdays, by hand and with the solution

By hand (estimated split)With automation (design estimate)
Reading and mapping each question2 days0.25 days
Finding old answers and evidence4 days1 day
Chasing owners6 days3.5 days
Checking figures and claims2 days1 day
Approvals2.5 days2.25 days
Writing back and submitting1.5 days0.5 days

Illustrative · replace with your own numbers · Neither column is a measurement. Time your own forms, and measure the second column in a pilot.

Show the numbers
By hand (estimated split)With automation (design estimate)
Reading and mapping each question2 days0.25 days
Finding old answers and evidence4 days1 day
Chasing owners6 days3.5 days
Checking figures and claims2 days1 day
Approvals2.5 days2.25 days
Writing back and submitting1.5 days0.5 days

Finding the cost of your last five ESG questionnaires

CostWhere it hidesHow to find your number in a week
Lead's timeEvenings before each deadline, never booked to anythingAsk for a rough day count on the last five forms, from receipt to submission.
Owners' timeEHS, procurement, HR and legal inboxesCount the email threads per form and how many people each one reached.
Figure driftOld forms in account foldersPick three key figures and compare them across your last ten submissions.
Stale evidenceAttached PDFsList your policies and their review dates, then count how many that had passed their review date went out this year.
Risky claimsReused wordingSearch past answers for "carbon neutral", "climate neutral" and "offset". Ask counsel to read each hit.
Tenders and ratings at stakeAccount plansAsk account teams which contracts carried a sustainability weighting, and how much.

Four sustainability answer costs a calculator misses

Credibility with a customerA buyer who finds two values for one figure starts to doubt the rest of the form.
Your experts' goodwillAn EHS director chased for the same figure each month will stop treating the request as urgent.
A public contradictionA figure in a filed report, a rater's database and a customer's Scope 3 calculation can differ, and anyone may notice.
What leaves with the leadWhen your ESG lead moves on, the memory of why each answer reads as it does goes too, unless it is written down.
19 · Your return

Your return on automating ESG questionnaire responses: days back, fewer corrections

In shortThe return you can count comes from workdays per form and fewer wrong answers. The rest, such as tender weightings and rating movement, is real and much harder to attribute. The calculator counts the first two. Replace each illustrative input with your own. Any return that rests on a number you cannot measure in a pilot is a guess.

Four places a questionnaire library pays back

Lead time

Reading and finding, done on arrival

The form is read, mapped and filled from the library before anyone starts on it.

requests × workdays saved per request × loaded cost per workday
Owner time

Fewer people chased, less often

Each owner gets only the gap or the flag, with the evidence attached.

requests × owner hours avoided × owner hourly cost
Corrections

Wrong figures stopped before they leave

A figure stopped at drafting costs minutes. One found by a customer costs a note, a call and an explanation.

corrections avoided × cost of each correction
Reach

Forms you can now afford to answer well

Teams at capacity answer the loudest requester. With time back, you can answer the ones that decide tenders.

tenders kept × margin, if you can attribute it. Most cannot.

Your workdays back across a year of sustainability questionnaires

The 18 workdays and 10 requests are the Conference Board's April 2018 averages, and the brief does not say whether its days are elapsed or full effort. The 9 is an estimate, half of that figure. The rest are illustrative. Replace them all.

Your season
Corrections
Illustrative yearly value
Workdays spent today0
Workdays freed0
Time freed, valued$0
Corrections avoided, valued$0
Yearly value before cost of the software$0

Workdays spent = questionnaires × workdays today. Workdays freed = questionnaires × (workdays today − workdays with automation). Time freed, valued = workdays freed × loaded cost. Corrections avoided, valued = corrections × share avoided × cost of one. The workdays are capacity freed for harder questions. They do not mean fewer staff.

20 · Readiness check

Is your ESG reporting team ready? Eight scored questions on figures, policies and owners

In shortEight questions, scored 0 to 2, and one for reflection. A low score points to foundations to fix first, and fixing them pays back with or without software. Your answers stay on this page.

1
Questionnaires a year

How many sustainability questionnaires, ratings and customer forms did you answer last year?

Why it mattersThe more forms you answer, the more each day saved per form adds up. Below a handful, a good shared document may be enough.
A strong answer"Fourteen, listed by requester, with five more through account teams we only learned about later."
2
One register of figures

Is there one place that holds the current value, method and assurance status of each key figure?

Why it mattersSoftware can only check against a truth you hold. Two sources give two answers.
A strong answer"The EHS system holds the inventory. Assurance status and restatements are recorded beside it."
3
Published report

Do you publish a sustainability report with an index of what it covers?

Why it mattersA published report is the base most answers cite. It already went through review.
A strong answer"Annual report with a GRI index, published each June, with the assurance statement attached."
4
Policy review dates

Can you list your policies and statements with an owner and next review date?

Why it mattersA stale policy is the quietest error here. It needs a date to be caught.
A strong answer"Twenty documents, each with an owner, and a reminder 60 days before review."
5
Who owns each topic

Does each questionnaire topic have one named owner who can approve an answer?

Why it mattersRouting needs an address. Without one, every question comes back to the lead.
A strong answer"Seven sections, each with a named owner and a deputy, and a two-day approval rule."
6
Claim rules

Does counsel have written rules for environmental claims, and do they reach questionnaire answers?

Why it mattersA list of risky words is what a check enforces. Rules that cover only marketing leave forms exposed.
A strong answer"A blocked list and approved wording, with counsel's second approval on any public claim."
7
Who holds which figure

Could you list everyone who received your last emissions figure?

Why it mattersA correction needs a list. Past forms are the raw material for one.
A strong answer"Yes. Past submissions are in one folder, with date, requester and account lead."
8
Owner and budget

Is there one owner and a budget for this work?

Why it mattersThis work crosses EHS, procurement, legal and sales. Without an owner, a pilot stalls at the first disagreement.
A strong answer"The head of sustainability owns it with a set budget, and counsel and the account teams have agreed the approach."
9
For reflection

If your inventory were restated tomorrow, how long would it take to list every open form and every customer holding the old figure, and to draft what you would tell them?

Why it mattersYour answer lists the gaps, and each gap is a job for software or a better procedure.
A strong answer"Under an hour, with a list and a draft note for each account lead."
0–6

Explore

Fix the foundations first: one register of figures, one list of policies with dates, named owners, and a folder of past forms. These pay back with or without software.

7–11

Ready to pilot

Run a measured pilot on three to five past questionnaires, whose answers you can check. Plant a stale figure and an expired claim, and see what gets caught.

12–16

Ready to implement

Plan the full library: your owners and claim rules as settings, links to your EHS and policy systems, and a rollout requester by requester.

21 · Questions for any vendor

Questions to ask any ESG questionnaire software vendor about citations, restatements and claims

In shortAsk these of anyone selling this kind of tool, including us. Good answers come with a demonstration on one of your own past forms. A vendor who answers with an auto-fill percentage on its own sample has yet to test your work.

A

Reading and matching a questionnaire you bring

A1

Run our last customer form. How many questions match the right topic, by our count?

Why it mattersA wrong match gives a confident answer to the wrong question.
Strong answer · warning sign
Runs it, and shows each match for you to score.
A demo on its own sample only.
A2

What happens to a question nothing in the library answers?

Why it mattersA plausible invented answer is the most damaging output.
Strong answer · warning sign
It says so, and routes it to a named owner.
"It always gives a best-effort answer."
B

Citing and checking each sustainability figure

B1

Show the passage behind this sentence. What stops a citation that does not support it?

Why it mattersA link can point to a passage that does not support the sentence. Legal research tools built on retrieval still gave incorrect or unsupported answers.44
Strong answer · warning sign
Opens at the passage, and describes its check.
Cites a whole document.
B2

We restate a figure. Show what happens in open forms, and in ones already sent.

Why it mattersThis is the event spreadsheets handle worst.
Strong answer · warning sign
Updates open forms, drafts corrections, records it all.
"You can search and replace."
C

Environmental claims and stale documents

C1

Add our blocked wording. Plant an expired carbon-neutral answer in the past responses. What happens?

Why it mattersRules differ by audience, so the list must be yours.
Strong answer · warning sign
Stops it, and asks your counsel.
Reuses it because it was approved once.
C2

Does a policy past its review date flag every answer that cites it?

Why it mattersNothing else in the file looks wrong when this happens.
Strong answer · warning sign
Flags each one, and re-checks them when the new policy lands.
A reminder to the policy owner only.
D

Formats, portals and who approves

D1

Can it write back into our customer's own file, and handle a rating portal's export?

Why it mattersCustomers expect their own layout and numbering.
Strong answer · warning sign
Shows the returned file, with numbering intact.
"Copy from our screen into theirs."
D2

Can an unapproved answer ever leave?

Why it mattersA skippable approval step lets a wrong answer out under deadline.
Strong answer · warning sign
Only a marked review copy.
An "export anyway" button.
E

AI, your data and security evidence

E1

Where do our documents and draft answers go, and are they used to train anything?

Why it mattersUnpublished data and contract terms are sensitive.
Strong answer · warning sign
A clear answer in the contract.
Vague terms that change by reference.
E2

Are you "ESG compliant" or "GxP certified"?

Why it mattersNo such certificate exists for a product. Security audits are real, and you can ask to see them.
Strong answer · warning sign
Names its audit reports and its controls that support your compliance.
"Yes, we're certified."
22 · A pilot on past forms

An 8-week pilot on your past ESG questionnaires, with results you can score

In shortPilot on three to five past forms whose answers you can check, including one with a known restatement. Add one live form if the first results hold. Keep your owners approving, and decide on numbers you set before you began.

Past forms give you a scored result by week 5, and a live form runs from there to week 7
Your teamVendor
Baseline and scoring rules
Load report, policies, inventory, past forms
Set owners and claim rules
Run 3–5 past forms and score them
One live form in parallel
Measure and decide
Week 02468

Illustrative · replace with your own numbers

Show the numbers
ActivityFromTo
Baseline and scoring rules02
Load report, policies, inventory, past forms02
Set owners and claim rules13
Run 3–5 past forms and score them35
One live form in parallel57
Measure and decide78

Measures that decide a questionnaire pilot

MeasureHow to take itDecide against
Questions matched correctlyYour lead scores each match on past formsA rate you set first
Filled from the libraryShare of questions answered on arrival, and share of those approved unchangedThe design target of 80% or more, on your own forms
Planted errors caughtPlant an old figure, an expired claim, a stale policy and a partial answerAll of them
Citations that holdSample 50 statements and read the passage behind eachCounsel's threshold
Workdays per formTimed by your team, including approvalYour timed baseline
Owner turnaroundHours from routing to approvalYour two-day rule, or your own
Deeper questions to settle before you start
  • Which requesters go first? A customer spreadsheet tests more of the work than a rater's portal.
  • Who decides when two approved answers disagree, and which one becomes the library answer?
  • How long may an approved answer be reused before its owner sees it again?
  • Which figures must carry an assurance status, and who records it?
  • What do you tell a customer who holds an old value, and who sends it?
  • Which product-level questions can you honestly answer today, and which need a plan?
  • How will you store unpublished data used in the pilot, and what happens to it afterward?
23 · Questions buyers ask

ESG questionnaire, supplier assessment and carbon-neutral questions, answered

In shortTwelve common questions about sustainability questionnaires, the rules behind them and the software, each with a short answer. Status is as of November 3, 2026.

What is an ESG questionnaire?

An ESG questionnaire is a form that asks a company about its environmental, social and governance record, such as emissions, water, supplier audits and ethics. Rating providers, disclosure platforms, customers, tenders and investors send them. A drug company may answer more than ten a year, each in its own format.

What is a supplier sustainability questionnaire?

It is a customer's own form asking a supplier about its sustainability record, often before or during a contract. In healthcare, hospital groups, purchasing organizations and national tenders send them. The answers can carry weight: NHS procurements include a minimum 10% net zero and social value weighting, according to NHS England's June 2026 roadmap.

How long does it take to answer an ESG questionnaire?

The one public figure we found is an average of 18 workdays per response, from a Conference Board survey of more than 70 senior managers published in April 2018. We found no newer independent measure. A short data review takes far less and a long disclosure far more, so time your own forms.

What is ESG questionnaire response software?

It is software that helps a company answer sustainability questionnaires from one approved source. A sound tool reads the form, matches each question to a topic, reuses or drafts an answer with citations, and checks figures and claims against current evidence. People then approve what is sent.

Must a company answer every ESG questionnaire?

Generally no law requires a company to answer a rating firm or a customer's form, though a contract or tender may make it a condition. In the EU, Directive (EU) 2026/470 lets a company of 1,000 or fewer employees decline information beyond the voluntary standard when the request is for a large company's reporting under the EU's sustainability reporting law (CSRD). The right arrives through national law, due by March 19, 2027, and does not, on our reading, cover other purposes such as a tender.

Can we still say carbon neutral in a questionnaire?

Only if it is true today and you can show what the phrase means for you, and counsel should read it first. The EU ban in Directive 2024/825, applying from September 27, 2026, targets consumer claims about products based on offsets. FTC Green Guides also apply to business-to-business transactions in the US, and a German court required an explanation of "climate neutral" in a trade-press advertisement itself.

What should you do when an emissions figure is restated?

Record the new value, its method and its status in one place, and update every open form that asks it. Then list everyone who received the old value and send a short correction that explains the change, for example a plant sale that triggered a recalculation under the GHG Protocol. Keep a record of what you sent, and to whom.

What is the difference between Scope 2 market-based and location-based?

Both measure emissions from purchased energy. Market-based reflects the contracts a company bought, such as renewable electricity. Location-based uses the average mix of the local grid. A company can report different totals on each, so an answer should say which method it uses.

What do NHS suppliers need to do from April 2027?

NHS England's roadmap says suppliers will publicly report targets and emissions and publish a carbon reduction plan for all relevant global Scope 1, 2 and 3 emissions, under proportionate requirements. A law firm's summary of NHS England's guidance says this applies to new procurements of £5 million a year or more, and to new frameworks where proportionate. Product-level footprints are planned from April 2028, with scope and method still to be determined.

Can a rated company correct an ESG rating?

Under the EU's ESG ratings regulation, which has applied since July 2, 2026, a rated company should be able to see the dataset used and point out factual errors, and providers must have a complaints process. That is a fact check, and the regulation says it gives no influence over the method or the outcome. Outside the EU, ask each provider for its own process.

Can AI answer an ESG questionnaire on its own?

It can draft, but a person should approve. AI is strong at reading forms, matching wording and reusing cited text. It is weak on new questions and on judging claims. Researchers testing legal tools built on retrieval found incorrect or unsupported answers 17% to 33% of the time, so a citation alone proves nothing until someone checks the passage.

Is ESG questionnaire software GxP certified or ESG compliant?

No software can hold those labels. GxP quality rules and FDA's Part 11 on electronic records apply to how a company uses a system in regulated work, and a sustainability answer usually sits outside them. Ask a vendor for its security audit reports, such as SOC 2 Type II, and for its controls that support your compliance, such as named approvers and an audit trail.

24 · Summary and glossary

ESG questionnaire response on one page: the method, the November 2026 rules and the terms

Print this page

In shortThe whole guide on one screen: the method, the rules as of November 3, 2026, the readiness scale and the terms.

The method
  1. Keep one approved answer per topic, each statement cited to its passage.
  2. Keep one register of figures, with method, status and date.
  3. Read each new form, and match each question to the topic it asks about.
  4. Reuse what is current. Send what is new or risky to a named owner.
  5. Check each figure against the register, and each claim against your rules.
  6. When a figure changes, update open forms and correct what has been sent.
  7. Send only approved answers, in the requester's format, and keep the record.

Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.

As of November 3, 2026: EU reporting scope cut by Directive 2026/470, national law by March 19, 2027 · EU due diligence applies from July 26, 2029 · EU ESG ratings rules apply since July 2, 2026 · EU consumer green-claims rules apply since September 27, 2026 · California SB 253 first report November 10, 2026, SB 261 stayed · SEC climate rule never in effect, rescission proposed · NHS global emissions from April 2027, product footprints planned from April 2028 · EU Green Claims proposal not law · draft EU GMP Annex 22 still a draft and aimed elsewhere.

14 terms
ESG
Environmental, social and governance.
Disclosure platform
A body that collects and scores a standard yearly response.
Data review
A rater's request to confirm what it already holds.
Scope 1, 2, 3
What you burn yourself, the energy you buy, and the rest of the value chain.
Market-based
Scope 2 counted from the energy contracts you bought.
Location-based
Scope 2 counted from the local grid's average.
tCO2e
Tonnes of carbon dioxide equivalent.
Base year
The year a company measures progress against.
Restatement
A corrected figure for a past year.
Limited assurance
An independent check that found nothing suggesting the figures are wrong.
Offset
A credit for a reduction made outside the company.
Greenwashing
Claiming more for the environment than the evidence supports.
Value-chain cap
The EU limit on what CSRD reporters may require of smaller companies.
Evidence library
Approved answers, each linked to its source passages.
25 · Sources

Sources

Accessed November 2026. Status statements on rules, frameworks and rating bodies are as of November 3, 2026.

  1. The Conference Board, "ESG Rating and Ranking Initiatives", April 20, 2018. conference-board.org
  2. GHG Protocol Corporate Standard, revised edition, chapter 5. ghgprotocol.org
  3. ERM, "Demand for ESG ratings remains strong…", December 9, 2025. sustainability.com
  4. NHS England, Net Zero Supplier Roadmap, June 2026. england.nhs.uk
  5. Directive (EU) 2024/825. publications.europa.eu
  6. Mayer Brown, October 27, 2026. mayerbrown.com
  7. CDP, "Disclosure 2026", read November 3, 2026. cdp.net
  8. EcoVadis, suppliers page, read November 3, 2026. ecovadis.com
  9. ERM, Rate the Raters 2025 corporate survey results, December 9, 2025. intelligence.sustainability.com
  10. Pharmaceutical Supply Chain Initiative. pscinitiative.org
  11. Access to Medicine Foundation, Index page. accesstomedicinefoundation.org
  12. Sustainable Markets Initiative Health Systems Task Force, open letter on supplier targets, July 2023. assets.roche.com
  13. Sustainable Markets Initiative Health Systems Task Force, open letter to supplier partners, November 21, 2025. a.storyblok.com
  14. Directive (EU) 2026/470. publications.europa.eu
  15. Regulation (EU) 2024/3005. publications.europa.eu
  16. Pinsent Masons, on NHS England's 2027 carbon reduction plan guidance, June 11, 2026. NHS England's own page would not open for us, so we did not read it. pinsentmasons.com
  17. Vinson & Elkins, October 19, 2026. velaw.com
  18. Regulation (EU) 2025/40. publications.europa.eu
  19. Regulation (EU) 2024/3015. publications.europa.eu
  20. Directive (EU) 2024/3019. publications.europa.eu
  21. European Commission, corporate sustainability reporting page. finance.ec.europa.eu
  22. White & Case, on the state regulator's reporting guidance of September 1, 2026 (we read an excerpt, not the full page, which would not open). whitecase.com
  23. Crowell & Moring, October 23, 2026. crowell.com
  24. Cooley, June 3, 2026. cooley.com
  25. Stibbe, June 29, 2026. stibbe.com
  26. GHG Protocol, Scope 2 Market-based Method Update, October 16, 2026. ghgprotocol.org
  27. IETA, June 11, 2026. ieta.org
  28. SBTi, Corporate Net-Zero Standard V2 FAQs, and its transition note, June 2026. FAQs · transition note
  29. Sustainable Markets Initiative release, BioSpace, November 3, 2022. biospace.com
  30. NHS England, Delivering a Net Zero NHS, first issued 2020, this file July 2022. england.nhs.uk
  31. NHS England events, "DRAFT - 2028 market insights survey", June 2026 (we read an excerpt, not the full page, which no longer opens). events.england.nhs.uk
  32. Bundesgerichtshof, judgment I ZR 98/23, as reproduced at gesetze.co; beck-aktuell, June 28, 2024. beck-aktuell.de
  33. 16 CFR Part 260, edition of January 1, 2025. govinfo.gov
  34. UK CMA, Green Claims Code, September 20, 2021. gov.uk
  35. FTC, Green Guides page. ftc.gov
  36. CMS, "The Green Claims Directive: a legal update", September 11, 2025. cms.law
  37. European Parliament, Legislative Observatory, 2023/0085(COD). oeil.europarl.europa.eu
  38. McCann FitzGerald, May 27, 2026. mccannfitzgerald.com
  39. European Parliament, Legislative Observatory summary. oeil.europarl.europa.eu
  40. UK Home Office, Transparency in supply chains, updated December 1, 2025. gov.uk
  41. KPMG, Defining Issues, April 2026. kpmg.com
  42. CDP help center, KA-01079. help.cdp.net
  43. The Conference Board, "ESG Initiatives Survey Findings", May 17, 2018. conference-board.org
  44. Magesh et al., J Empirical Legal Studies, April 23, 2025. nlp.stanford.edu Preprint: arxiv.org
  45. European Commission, AI framework page (SETTLED). digital-strategy.ec.europa.eu
  46. FDA, AI draft guidance, January 2025. fda.gov
  47. Draft EU GMP Annex 22 (SETTLED). picscheme.org
  48. EudraLex Volume 4 (SETTLED). health.ec.europa.eu
  49. FDA, Computer Software Assurance (SETTLED). fda.gov
  50. MHRA, GXP data integrity guidance (SETTLED). gov.uk
Next step

See it on your own questionnaires.

Explore the solution, or bring one past questionnaire and your published report, and we will fill it from a library with you, every statement cited to its passage.

botminds.ai The complete guide to ESG questionnaire response · November 2026. Northwind Bio, every requester, person, document, date and figure in the example and the screens are fictional, and no real company's rating or score is stated or implied. Regulatory and framework status is as of November 3, 2026; check the sources before relying on it.