This is a publication that is part of RSM’s Voice of SCM. On a monthly basis, RSM issues the Voice of Supply Chain Management (SCM). Our SCM consultants constantly follow global SCM developments in an ever-changing society and translate their impact into practical considerations for internationally active companies. 

Suppliers that can substantiate their environmental, social and governance (ESG) performance may be better placed to win public contracts under the European Commission's proposed Public Procurement Act. The proposal would allow public buyers to give more weight to ESG considerations, innovation, security and resilience. Public authorities across the European Union (EU) spend trillions of euros each year on goods, services and works, giving their purchasing decisions considerable influence over markets and investment. In September 2026, the European Commission's [LINK: Public Procurement Act proposal, European Commission proposal page, COM (2026) 590] set out how procurement could support wider policy objectives, simplify procedures and accelerate digitalisation.

This article was written by Kirill van der Velde (kvandervelde@rsmnl.nl) and Bart Ladru (bladru@rsmnl.nl). Kirill and Bart are consultants with RSM Netherlands with a focus on ESG and supply chain management.  

How the proposal could change public procurement

The proposal remains subject to the EU legislative process. It would enable public buyers to consider environmental, social, innovation, security and resilience factors more consistently throughout procurement procedures, within a more coherent framework for public purchasing. For suppliers, this could make ESG capabilities more relevant to tender eligibility, evaluation and contract awards. Businesses would need to explain how those capabilities improve performance, manage risk and create long-term value, alongside meeting their compliance and reporting obligations.

Why ESG performance could become more important in public tenders

Many organisations have spent the past decade investing in climate disclosures, human rights due diligence, supply chain transparency and responsible governance. These programmes have often been managed primarily as compliance or reporting obligations. The proposed reforms would give procurement authorities more scope to take that work into account when assessing suppliers and pursuing the EU's environmental, social, innovation and economic resilience objectives.

Technical capability and price would remain important. Buyers are also likely to seek greater assurance that suppliers can deliver sustainable outcomes, manage operational risks and support responsible, resilient value chains. Credible evidence of these capabilities may help suppliers distinguish their bids.

Which sectors could be most affected?

This is particularly relevant to sectors with substantial public sector business, including infrastructure, construction, transport, energy, professional services, technology and manufacturing. Many businesses in these sectors already receive growing requests for ESG information from customers and investors. Public procurement could give them a further commercial reason to improve their data, governance and sustainability performance.

What are public buyers likely to look for?

The proposal points to a greater role for non-price factors in procurement and contract awards, although its provisions may change during negotiations between the European Parliament and Member States. Public buyers are likely to pay closer attention to the following areas:

  • Carbon footprint management: credible measurement, emissions reduction programmes and evidence of progress towards climate targets, particularly where operational and supply chain emissions account for a significant share of a project's impact.
  • Circular economy performance: resource efficiency, waste reduction, product durability, repairability, reuse and responsible management of materials throughout their lifecycle.
  • Supply chain transparency: visibility into supplier networks, traceability of key products and materials, [LINK: supply chain due diligence, RSM ESG and sustainability service page] processes, and the identification and mitigation of environmental and social risks.
  • Social sustainability: workforce wellbeing, health and safety, diversity and inclusion, labour conditions and contributions to communities and society.
  • Governance and accountability: effective oversight, ethical business conduct, risk management and reliable, auditable ESG information.
  • Resilience and security: business continuity planning, cybersecurity, security of supply and the ability to manage disruptions to critical operations and supply chains.

These areas overlap. Reliable sustainability data and operational controls can support several procurement requirements, while a weakness uncovered in one part of a supplier assessment may raise questions about others.

How can suppliers prepare for changes in EU public procurement?

Customers and investors increasingly expect evidence of ESG progress and performance to support sustainability commitments. Public buyers are likely to make similar demands because they must justify contract awards through objective, transparent evaluations. Suppliers may therefore need measurable evidence for their environmental and social claims. Many organisations already have sustainability initiatives but struggle to collect, validate and explain the relevant information consistently. Emissions data, supplier due diligence, workforce metrics and circularity measures often sit in separate functions and systems. Suppliers need to bring this information together so that buyers can assess the outcomes and verify the evidence. That requires sustainability, procurement, supply chain, finance, operations and executive management teams to work together.

Turning ESG performance into credible tender evidence

The implications extend to how organisations assign responsibility for ESG. Dedicated sustainability and compliance teams remain essential, but their work also has commercial uses. Evidence of environmental and social performance can influence customer relationships, investor confidence, access to capital and public sector opportunities. Organisations are beginning to use sustainability information in sales conversations, tender submissions and strategic account management. This can help them identify opportunities and respond to customer expectations. It also changes how they assess investment in ESG programmes: better emissions data, stronger supply chain oversight and circular business models may improve their ability to compete for contracts as well as meet regulatory requirements.

The legislative process will continue over the coming years, and the proposal may change before a final framework is agreed. Businesses can still prepare by improving ESG data systems, supply chain visibility and governance, and by incorporating sustainability into operational decisions. This work takes time. Starting early gives suppliers more time to assemble evidence and address weaknesses before new procurement requirements apply. Price will remain important, alongside sustainability, resilience, innovation and long-term performance. For companies seeking public contracts, the practical task is to connect their ESG work to the outcomes buyers assess. Reliable evidence of sustainability performance, transparent value chains and resilient operations may strengthen a bid and help buyers assess a supplier's suitability as a long-term partner.

RSM is a thought leader in the field of supply chain management including ESG. We provide frequent insights through training and thought leadership, based on detailed knowledge of industry developments and practical application gained from working with our clients. RSM helps companies connect individual geopolitical and regulatory developments to the broader changes affecting their supply chains. By doing so, we support businesses in distinguishing short-term disruption from structural change and translating that assessment into coordinated decisions on sourcing, origin, landed cost, logistics and supply chain design. If you would like to discuss what these connected developments mean for your business, please contact one of our consultants. 

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