completing a sustainability questionnaire for the first time, where do I start
The VSME baseline module covers most questions
With a second or third sustainability list, the pattern is usually already familiar: first company details, then energy and emissions, then personnel and policy. Those who recognize that structure can switch faster. The EFRAG VSME baseline module is de facto the format most customer portals are based on, even if the portal itself uses different labels. What one portal calls "Scope 1 and 2" appears in the next simply as "direct and indirect emissions" — the underlying question is identical.
Where things more often go wrong is evidence: filling in an answer is one step, providing the underlying documentation is another. For emissions figures that's usually an energy bill or a calculation based on consumption; for policy an internal document, not necessarily a certificate. If a customer asks for certification when it doesn't exist, the answer is simply no — not "partial" or "in preparation", because that's not a fact but an intention. Two categories of questions recur in almost every list and are quick to identify: the number of employees and the countries where the company has establishments. These two often also determine which follow-up questions a portal displays.
Origin: CSRD, VSME and implementation in SMEs
The CSRD (Directive (EU) 2022/2464) requires large, listed enterprises to report, but the questionnaires that reach suppliers are usually a translation of that obligation down the chain: the large customer must themselves report on their chain and therefore asks questions through. EFRAG has drawn up the VSME standard for non-listed SMEs, precisely to prevent each portal from inventing its own structure. That is also why many questionnaires, despite different branding, follow the same basic layout.
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.