who is responsible for esg within the company question

Usually management, not a separate role

In most SMEs, responsibility for sustainability reporting lies with management or the board, not with a separately appointed ESG officer. The EFRAG VSME baseline module does not require a governance structure with separate roles, as the full CSRD does for large, listed companies. For an unlisted company that completes the voluntary standard, it is therefore sufficient to be able to name who within the company answers the sustainability questions and collects the data — a job title such as "ESG manager" is not a requirement.

What is often specifically asked, however, is whether there is a policy on specific topics, and who sets or reviews that policy. This overlaps with questions you encounter more frequently in ESG questionnaires from banks and insurers on governance: for example who sits on the board and how it is composed, or whether there is a whistleblower procedure. These questions do not come from the VSME module itself, but appear because questionnaires often combine topics. If you do not have a separately appointed person, the answer is usually: state the role (for example "management" or "controller") instead of a name, and answer "yes" only to what you can support with an internal document.

Where this difference between CSRD and VSME stems from

Directive (EU) 2022/2464, the CSRD, requires large and listed companies to engage in comprehensive reporting with governance requirements. The EFRAG VSME baseline module is derived from this but is voluntary and simplified for unlisted SMEs, and does not require a specific internal role or function. This explains why a questionnaire based on VSME usually only asks whether a policy exists and who manages it — not who the "ESG officer" is.