Having recently joined a strong line-up of corporates, academics and business associations at the Westminster Business Forum’s conference on the future of non-financial reporting (AKA sustainability reporting), I want to share my reflections on standing up for the missed middle at this policy conference.

The focus of the conference was UK SRS – the UK’s new sustainability reporting standards – which will shortly become mandatory for listed companies in the UK.  Whilst most speakers represented larger businesses, my contribution focused on a group that sits outside the direct scope of UK SRS but will feel its effects keenly: the ‘missed middle’ – mid-sized businesses that are too large to benefit from SME exemptions, but which don’t have the sustainability reporting infrastructure of a large corporation.

You might ask: if mid-sized businesses don’t explicitly fall under the scope of SRS, why is this relevant to them? In order to report their Scope 3 emissions, listed companies will need decision-useful sustainability and carbon data from their supply chains. And it’s not just UK listed companies – any company with a Science Based Targets initiative (SBTi) target or mature sustainability strategy will also require data from their supply chains. There’s a significant waterfall effect when larger companies need to provide data — because those requests quickly make it through to their suppliers, many of which are mid-sized businesses with no regulatory obligation of their own.

A recent report, From Burden to Benefit, found that 37% of SMEs are already being asked for carbon data by clients, and 60% of those found it difficult or very difficult to respond. Multiply that by however many large clients a mid-sized business serves, and you get a real and growing burden falling on exactly the businesses least equipped to absorb it — not because they lack the will, but because they lack the knowledge, the confidence and the resources.

Disclosure frameworks such as SRS follow a principle known as ‘interoperability’ which is intended to reduce the burden on reporting companies by ensuring that differing disclosure frameworks align with each other. Somewhat ironically, there is currently no mechanism for ‘interoperability’ to reduce the burden on the supply chain of the reporting companies, who are least equipped to deal with it.

When large companies ask their suppliers for data, it often happens in a haphazard way – with each company developing their own questionnaire, or requesting their suppliers disclose via platforms such as CDP or Ecovadis.

The barrier that the missed middle face isn’t willingness; it’s a lack of coordinated, usable systems, and consistency in the way clients ask for things. There is also an additional and often overlooked barrier – confidence. The confidence to know when a client’s sustainability question is not relevant, or to read between the lines of what a one-size-fits-all questionnaire is actually asking for. So, why does all of this matter?

• For policy makers – It matters because there’s a big policy gap. Guidance and standards aren’t written for mid-sized businesses, and they are often under-represented in the consultation process — because they don’t have the time, or the knowledge, or feel that their voice is relevant.
• For large companies – It matters because a one-size fits all approach doesn’t work for the Missed Middle. Complex questionnaires with too many questions, overly technical questions or disproportionate questions will not achieve the results you want with your mid-size supply chain.
• For the missed middle – It matters because these companies might feel that they don’t know how to address these multiple and differing requests – which are not interoperable. Don’t worry – you are not alone!

At Not Sustainable, we work with mid-sized businesses every day, and we understand their needs. We advocate for them via consultations and engaging with policy makers and business associations. If you are a mid-sized business navigating sustainability data requests from your clients, reach out to us. And if you’re a large business that wants to engage your supply chain more effectively, or a policy maker wanting to ensure that the needs of mid-sized businesses are met, we’d love to talk to you too.

NOTES:

1. Things change quickly in sustainability, and sometimes it can be hard to keep up!  Having spoken about the waterfall effect of sustainability disclosures through the supply chain, the FCA then announced (1st October 2026) it would not require listed companies to disclose sustainability data and this would be done on a ‘comply or explain’ basis.  So does this change things for mid-sized businesses in the supply chains of listed businesses? Well…no! Why? Because by the FCA’s own reasoning, 92% of listed companies already report this information.
2. The panel discussion I participated in was “Implementation of UK Sustainability Reporting Standards: priorities, coordination and early experience”. Huge thanks to the other brilliant panellists: Sarah-Jane Denton (Travers Smith), Jessica Bingham (ACCA), Sana Mirza-Awan (The Investment Association) and Joe Dillon (E3G).