Big Fish Procurement Career Signals: CBAM and the Forced Labour Regulation — he value of experience depends on how supplier data is used in procurement decisions
Experience gained through CBAM implementation or forced labour risk assessment may look similar on a CV while reflecting very different levels of responsibility. The greatest career value is gained by professionals who use supplier data to help shape decisions on costs, sources of supply, contractual terms and category strategy.
The definitive CBAM regime has applied since 1 January 2026, while the Forced Labour Regulation will apply from 14 December 2027. The first regulation affects the economics of importing selected products; the second may prevent a product from being sold or exported. Both increase the importance of data on production methods, the origin of raw materials and further tiers of the supply chain.
The first edition of Big Fish Procurement Career Signals covers the use of AI in procurement, changes in the scope of procurement processes performed by SSCs and GBS organisations, and the impact of EU regulations on the importance of supplier data. The third signal concerns the experience gained when new requirements are translated into procurement decisions.
Category exposure determines the scope of experience gained
In one organisation, the regulations may result in an additional control process. In another, they may change the way a category is managed. The scope of the work depends on the value of imports, the structure of the supply chain, the availability of information, the cost of switching sources and the consequences that missing data or a confirmed violation may have for the company’s operations.
The most comprehensive experience is likely to be gained in organisations where the new requirements affect costs, the supplier portfolio, commercial terms or the ability to continue selling a product. Employees may then participate in assessing a category’s exposure, revising sourcing requirements, incorporating new data into cost models, developing alternative sources and negotiating contractual obligations for suppliers to provide information.
In companies with lower exposure, the work may focus on expanding documentation, checking the completeness of information and updating data in systems. This experience prepares employees primarily for roles related to compliance operations, data quality and process control. Responsibility for changing the source of supply, the cost base or commercial terms develops experience relevant to category management, supplier risk management and contract management.
When assessing a position, the scale of the project’s business consequences matters more than the name of the project. A reference to participation in a CBAM implementation reveals little without information about the category, the value of imports, the scope of responsibility and the decisions made on the basis of the data collected.
Regulations will broaden responsibilities and, in some companies, justify new roles
In most companies, the new obligations will broaden the scope of responsibility in category management, supplier risk management, sustainable procurement, contract management and Procurement Excellence. Large import volumes, a multi-tiered supply chain or high regulatory exposure may justify the creation of specialised roles combining procurement, analytical and regulatory expertise. The available sources do not yet make it possible to estimate how large this segment of the labour market will become.
In category management, data on emissions, origin and production methods will be incorporated into cost models, sourcing assessments and supply strategies. Responsibility for reallocating volumes, developing an alternative source, changing cost assumptions or renegotiating a contract develops experience relevant to roles involving end-to-end category management.
Supplier risk management will require organizations to determine what information they need, at which tiers of the supply chain it should be obtained and what action should be taken when data is unavailable or the level of risk is elevated. Combining this responsibility with the design of contractual terms, control rules and escalation routes prepares employees for roles in supplier risk, contract management and compliance.
Procurement Excellence may assume responsibility for data standards, process design, the control framework, tools and the allocation of responsibilities between procurement, finance, tax, legal and sustainability teams. A person leading this area aligns how these functions work with the same data and respond to identified risks.
The regulations will therefore increase demand for different professional profiles. Category professionals will connect the new data with costs and supply strategy. Risk and contract specialists will translate it into supplier qualification methods and commercial terms. Process-focused roles will be responsible for data reliability, the control framework and the consistency of activities across the organisation.
The scope of the project determines its career value
Employees build decision-making experience when, in addition to obtaining and checking data, they are responsible for assessing its reliability, preparing recommendations and implementing changes involving a supplier, a cost model or contractual terms.
A person working in a company affected by the regulations may broaden their experience by participating in an analysis of the regulations’ impact on a category, supplier segmentation, the development of a cost model, the negotiation of new contractual clauses or the development of an alternative source.
Projects of this kind combine category knowledge with data analysis, risk management and an understanding of the financial and operational consequences of decisions.
When evaluating a position or project, the answers to five questions will be particularly informative:
What consequences do the regulations create for the category and the company?
Who defines the scope of the required data and assesses its reliability?
Do the findings affect the cost model, the choice of source, volume allocation or contractual terms?
Does the responsibility cover an individual supplier, an entire category or several categories?
Who prepares the recommendation for change and who is accountable for implementing it?
When describing experience related to CBAM and the Forced Labour Regulation on a CV or during a recruitment interview, candidates should present the category, the scale of exposure, their scope of responsibility, the decision made and the result achieved. Knowledge of the regulations alone does not indicate the types of problems or roles for which a candidate is prepared.
Career capital consists of competencies, experience, documented results, reputation and relationships that retain their value when a person changes employers. Its value is reflected in the scope of responsibility an employee can credibly take on in another organization. It grows when successive roles expand the types of decisions made, the scale of the problems addressed and the level of accountability for results.
In the context of CBAM and forced labour, career capital grows with the ability to translate supplier data into changes to costs, sources of supply, contracts or category strategy. This type of experience remains valuable beyond any single regulation because it demonstrates the ability to integrate data, risk and procurement decisions.
Criterion: Signal strength
Assessment: 3/5
Criterion: Confidence level
Assessment: High regarding the expansion of responsibilities; medium regarding the impact on the labour market
Criterion: Impact horizon
Assessment: 0–24 months
Criterion: Procurement areas affected
Assessment: Category management, supplier risk management, sustainable procurement, contract management and Procurement Excellence
Criterion: Nature of change
Assessment: Regulatory, cost-related and competency-related
The 3/5 rating reflects regulatory certainty and the selective impact on the labour market. The definitive CBAM regime is in force, and the application date of the Forced Labour Regulation has been established. A change in the scope of responsibilities within companies affected by the regulations is highly probable. Its significance for individual professionals will depend on the category, the structure of the supply chain and the company’s level of exposure.
The available evidence does not yet confirm the emergence of a broad market for new roles or an impact on salary levels. It does, however, identify the areas in which regulatory experience may broaden future career opportunities.
Big Fish Procurement Career Signals combines the monitoring of economic data, industry information, regulatory developments, labour market research, corporate decisions and the ways in which procurement functions are organised with an in-depth verification of selected observations.
Developments are included in the publication when they are supported by several types of evidence or are consistent with recurring corporate decisions, and when a mechanism can be identified through which they may affect procurement and the value of professional experience.
Each signal is assessed in terms of the potential scale of its impact, the quality of the available sources and the time horizon within which the change may begin to influence processes, role scopes and recruitment criteria. A job title is a secondary indicator. The value of a role is determined by its scope of responsibility and the consequences of the decisions made.
Big Fish has specialised exclusively in the procurement market for more than 20 years. We conduct executive search and specialist recruitment assignments, assess competencies and support organisations in developing their procurement functions. We combine insights gained from our work with organisations and procurement professionals with systematic market analysis.
Big Fish Procurement Career Signals was created to bring structure to developments that may influence the scope of roles, demand for competencies and the value of professional experience in procurement.
Sources used directly in the analysis
The following sources provide the direct basis for the data cited in the article. They were selected from a broader set of monitored materials on the basis of their relevance, data quality and importance to the mechanism being analysed.
[1] European Commission, “Carbon Border Adjustment Mechanism” and “CBAM definitive regime” — the scope of the CBAM system and the start of the definitive regime on 1 January 2026.
[2] Regulation (EU) 2024/3015 of the European Parliament and of the Council of 27 November 2024 on prohibiting products made with forced labour on the Union market — the scope of the regulation and the consequences of a confirmed violation.
[3] European Commission, “What is the Forced Labour Regulation and how does it work?” and the guidelines concerning the implementation