why does the bank want to know exactly how many employees we have
Number of employees determines your company size category
The bank asks for the number of employees because this figure, together with turnover and balance sheet total, determines which category your company falls into: micro, small, medium-sized or large. The bank does not use this classification out of curiosity, but as a link in its own reporting chain. Banks themselves fall under the CSRD (Directive (EU) 2022/2464) and must report on their credit portfolio according to categories that align with the EFRAG VSME standard, the voluntary module for non-listed SMEs. Your number of employees is one of the three benchmarks in this.
This figure is therefore not an isolated question but part of the size questions that virtually every portal asks, together with the company's annual turnover. You best feed both figures from the same source as you once your registration number with the Chamber of Commerce provided: consistency between portals saves follow-up questions. Pay attention to the reference date and definition: some portals ask for FTE, others for headcount. If your file contains only a headcount number and the portal asks for FTE, that is a difference you must bridge yourself — the system recognizes the field, but does not convert it.
Where this comes from: the VSME size criteria and the Business Register
The link between number of employees and category classification is set out in the EFRAG VSME basic module, which banks use as a reference framework for their CSRD reporting on the credit portfolio. The number of employees itself is data that every company already records in accordance with the Dutch Trade Register Act 2007 (BWBR0021777); many companies derive this figure from the same source as their basic registration. A certificate or separate statement is not part of this — it is a factual figure, not an assessment.
What this is based on
- Trade Register Act 2007 — the data recorded for each company
- EFRAG VSME — the voluntary standard for non-listed SMEs, basic module
- Directive (EU) 2022/2464 (CSRD)
- ISO/IEC 27001 — Annex A, the control measures
- Directive (EU) 2022/2555 (NIS2), Article 21(2) — the ten measures
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.