questionnaire asks who within our company is responsible for esg, what do I enter if no one has that role

How to fill in ESG roles when no one holds that title

Enter who actually performs the task, not who holds the title "ESG officer" — that role does not exist at many SMEs, and that is not a problem for the answer. EFRAG's VSME baseline module asks about governance, but does not require a specific size or name for that role. At a small company, it is often the owner, the director or the controller who handles sustainability questions alongside other tasks. You can enter it that way: name or function, and a brief description of what that person does ("director, responsible for sustainability reporting alongside operational tasks").

If no one actually takes on that task — not even informally — then the answer "not yet assigned" is more precise than entering a name that does not fit. Customers who ask this question mainly want to know whether there is a point of contact, not whether a separate department exists. The same logic applies to related questions in the questionnaire: who sits on the board and how it is composed is often asked in the same section, and the way you describe the whistleblowing procedure follows the same principle: role and process over job title.

Are you unsure whether you are entering something that your company has agreed internally but never put in writing? Then enter what actually happens, with the name of the person who does it. An agreement that is not documented anywhere is still an answer — as long as it matches practice.

Where this follows from the VSME basic module

The VSME baseline module of EFRAG asks in the governance section about who within the enterprise is responsible for sustainability information, without prescribing a minimum organisational form. The standard was deliberately written for non-listed SMEs, which often do not have a separate ESG team — unlike the reporting obligations under Directive (EU) 2022/2464 (CSRD), which apply to larger, listed companies. For the SME receiving these questionnaires from customers, the VSME baseline module is therefore the relevant standard, and it asks for a factual description, not a formal structure.