Can multiple colleagues update the supply chain file simultaneously

Multiple contributors per file is the normal situation

Yes, multiple colleagues can work on the same supply chain file. That also makes sense, because the data in the file come from different parts of the business. The HR manager provides the answer on how many employees the undertaking hasthe facilities manager knows whether there is a business continuity plan in place, and the IT manager is best positioned to assess which of the ten measures from Article 21(2) of Directive (EU) 2022/2555 are already in place and which are not yet. One person filling this all in alone would be guessing or asking around — with multiple contributors, each answer goes to someone who actually knows.

The file is set up so that each answer has its own source and its own confirmation. This means that colleague A can confirm the answer about ISO 9001 without having to wait for colleague B who is updating the locations of operations. Working on the same file is therefore not the same as working on the same answer — the update of one does not block the other. However, this applies: whoever confirms an answer does so for the entire company. It is therefore advisable to be clear within the organisation about who is responsible for which part, even though this is not a technical limitation of the system.

What is fixed on this point and what is not

On this specific point — whether multiple users may work at the same time — there is no legal rule that prescribes or prohibits it; that is a matter of how the platform is built, not of a regulation or directive. What is fixed are the underlying sources that appear in the file per subject: the Trade Register Act 2007 for identity data such as the registered addressthe VSME Basic Module of EFRAG for sustainability figures, and Article 21(2) of Directive (EU) 2022/2555 for the ten cybersecurity measures. Who provides which part of those sources is an internal arrangement — not something that follows from those regulations themselves.