My client has sent me an ESG questionnaire: how to answer it with the VSME/VS

For many SMEs this has become a familiar scenario: a large client, a contracting customer or a buyer sends you a lengthy ESG questionnaire to complete, often against a deadline, sometimes as a condition for becoming an approved supplier. The question that follows is almost always the same: do you have to fill in everything, and how can you answer without spending weeks on it? The VSME/VS standard offers a practical answer here. It gives you a standardised framework to answer once and for all, and the European regulatory framework will, in time, give you an argument for not having more imposed on you than necessary.

Why you are receiving this questionnaire

You have probably not been singled out at random. Your client is most likely itself subject to sustainability reporting obligations – the CSRD for the largest companies – and has to report on impacts along its value chain, and therefore within its suppliers’ operations. Unable to produce this information on its own, it asks its partners for it. This is known as the knock-on effect: an obligation that applies to a large group spreads, indirectly, down to the SMEs that work with it.

This phenomenon has even intensified with the so-called Omnibus reform. Since Directive (EU) 2026/470 of 24 February 2026, the direct scope of the CSRD has been narrowed to companies exceeding two cumulative thresholds: more than 1,000 employees and more than €450 million in net turnover. Many large groups remain within scope and continue to survey their suppliers. The downward pressure, for its part, does not disappear – it simply changes shape.

The VSME/VS: a standardised answer rather than imposed bespoke reporting

The value of the VSME/VS lies precisely in the fact that it exists to address this situation. It is the voluntary sustainability reporting standard for SMEs, developed by EFRAG and endorsed by Commission Recommendation (EU) 2025/1710 of 30 July 2025. This soft-law instrument has had no legal effect since 24 September 2026: the voluntary standard of Delegated Regulation (EU) 2026/1560 has taken over – still voluntary, with no penalties and no mandatory filing. Its stated purpose is precisely to reduce the burden of the uncoordinated ESG requests that SMEs face.

In practice, VSME/VS structures information into two modules. The Basic Module brings together eleven disclosures (B1 to B11) covering environmental, social and governance matters: energy and emissions, workforce, health and safety, business conduct. The Comprehensive Module (C1 to C9) is added for companies ready to go further, particularly towards data expected by certain banks or major contracting customers. The standard requires neither double materiality nor a mandatory audit.

Rather than filling in by hand each proprietary questionnaire that arrives – each with its own headings and format –, the idea is to produce a core set of information once, in line with the VSME/VS, and then reuse it to feed successive requests. You answer in a recognised, comparable language, and you regain control over the content. To build this core set step by step, our guide applying the VSME/VS standard in an SME sets out the method and the data to gather.

The value chain cap: the most a client can ask of you

The most useful point for an SME receiving an overly burdensome questionnaire is a mechanism provided for by the Omnibus reform: the value chain cap. The principle: a company subject to sustainability reporting may not require companies in its value chain with 1,000 employees or fewer (on average over the previous financial year) to provide information going beyond the European voluntary standard (Delegated Regulation (EU) 2026/1560). In other words, for the purposes of its own reporting, a contracting customer cannot legitimately require more than this scope from a company of that size.

Directive (EU) 2026/470 (Omnibus I), adopted on 24 February 2026, enshrines it in Articles 19a and 29a of Directive 2013/34/EU (the Accounting Directive): when faced with a request made for the sustainability reporting of an in-scope company, protected companies have the right to refuse to provide information going beyond the voluntary standard; the requesting company must inform them of this right, and no contractual clause to the contrary is binding (the rest of the contract remains applicable). These provisions must be transposed into national law by 19 March 2027 at the latest. An exception is provided for information commonly shared within the sector. This cap refers to the voluntary standard, whose content was specified by a delegated act adopted by the Commission on 3 July 2026 – published in the Official Journal of the EU on 21 September 2026 (Delegated Regulation (EU) 2026/1560), in force since 24 September 2026, with its Article 3 applying to financial years beginning on or after 1 January 2027. This text does, however, make a decisive clarification: its Article 3(2) limits the cap to a closed list of datapoints (Annex II) – extracts from the Basic Module (B1, B3, B6 to B10) and only four disclosures from the Comprehensive Module (C1, C5, C6, C7), with a shorter list for companies with 10 employees or fewer. In other words, a client cannot demand the entire standard from you: the scope you can rely on against a client is narrower still. The protection would become fully operative once the directive has been transposed, expected by 19 March 2027 at the latest.

Caution is therefore called for regarding the timetable: at present, the cap is an adopted framework whose practical effect depends on transposition. The mechanism, its limits and its legal basis are set out in detail on our pillar page VSME/VS and the value chain: the value chain cap and responsible purchasing. Remember the underlying intent: the European framework tends to make the VSME/VS the right level of response, no more and no less.

Three rules of thumb for answering without overstretching yourself

When the questionnaire lands on your desk, a simple method helps you sort things out.

1. Answer with what you already have. A large share of the Basic Module data already exists in your accounts and payroll: energy consumption, headcount, training. A VSME/VS report relies first and foremost on documents you already hold.
2. Submit your standard report rather than filling in every box. When a request overlaps with the VSME/VS scope, attaching your structured report is often better than copying your figures into an in-house form. You save time and reduce transcription errors.
3. Politely set aside anything out of scope. If a question clearly goes beyond the VSME/VS framework and does not concern information commonly shared in your sector, you can explain that your answer is aligned with the European voluntary standard. This is a professional stance, not a refusal to cooperate.

Do you need a third party to validate your answers?

No, no statutory audit is required for a voluntary report. That said, if your client attaches importance to the reliability of the data, an accounting professional can make the process more robust: most of the information comes from your accounting records, and a chartered accountant is well placed to organise it and, where appropriate, offer a voluntary assurance engagement. We explore this option in the VSME/VS, a new engagement for accounting firms.

Key takeaways

A supplier ESG questionnaire is not a constraint to be endured box by box. It is an opportunity to build, once, a core set of information in line with the VSME/VS that can be reused with all the parties you deal with. The Omnibus framework, through the value chain cap, points in the same direction: limiting what a large client can require of an SME. Not sure whether this applies to you before you start? Begin with Does the VSME/VS apply to me?, then come back to build your answer.