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The EU’s biggest ESG enforcement tool is the tender on your desk 

Our Head of Group ESG, Giulia Modolo, reflects on how ESG regulation is reshaping procurement – and why tenders may become one of the EU’s most powerful tools for turning sustainability goals into measurable business requirements.

I hold the sometimes unpopular view that ESG regulation is good for business. Maybe that’s because my career started when regulation was thin and fragmented, or because I spent too much time answering obscure ESG questionnaires. Either way, from a vendor perspective, it is clear that the recent waves of regulation have accelerated alignment, giving customers a common language and more defined objectives. This makes my role both rewarding and challenging.

At Conscia, customers are at the heart of everything we do. The organisations we serve – some of Europe’s largest private companies and public institutions – have already made ESG part of their criteria for choosing vendors. However, we are still seeing gaps in how performance is measured, and that’s where tenders come in. 

Why ESG criteria are becoming more consistent in procurement

What is encouraging is that ESG requirements are becoming more consistent.

Across tenders, RFPs, investor questionnaires and customer assessments, priorities are converging:

• SBTi-aligned decarbonisation plans backed by audited emissions data
• Meaningful supply chain due diligence and worker protection measures
• A responsible approach to data centres, AI and data privacy
• Independent assurance through frameworks such as EcoVadis, CDP, SBTi and ISO 14001

Whether the request comes from a private company, an investor or a public authority, the direction of travel is remarkably similar. The end goal might be clear, but the evaluation criteria is not.

Why regulation is pushing ESG into business operations

As a change management practitioner, I see regulation as one of the reasons for this convergence.

Even if the scope of CSRD was later narrowed, the original legislation created the increased awareness that many value chains needed. Reporting requirements may be the stick that drives better data and governance, but tenders are the carrot – they reward organisations that have already integrated ESG into their operations. 

That is where real change happens.

Procurement as the next ESG catalyst

The next shift will likely come from public procurement, as we have already seen with the UK’s 2023 Procurement Act.

We still see very different interpretations of social sustainability across Europe, with some markets focusing on community impact and inclusion and others on human rights in supply chains.

The leaked draft of the EU’s proposed Public Procurement Regulation (expected in September) appears designed to bring greater consistency in exactly these areas. By replacing three procurement directives with a single regulation and placing more emphasis on sustainability, resilience and social outcomes, it could move procurement further away from lowest-cost decisions – and provide more clarity for vendors on what “good” looks like.

If that happens, ESG stops being a differentiator in public tenders and becomes a licence to compete. Not only that, it also gets a clear, measurable score.

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