can a colleague or advisor do this on my behalf
A colleague or adviser can do the filling in
Yes, that is possible, and in practice it often happens. The questionnaire itself does not impose any requirements as to who enters the answers or operates the client's portal. What does matter is that the content of the answers is correct and that someone within the company — usually the person responsible for it — checks them before they are submitted. Who does this checking is an internal choice, not a legal requirement.
Where the line is actually drawn: a colleague or adviser who fills in answers does so on behalf of the company. Facts such as the registration number, turnover or the number of employees must come from the chain file, not from the memory of whoever happens to be at the keyboard. If there is any doubt or unclearness about an answer — for example because the adviser cannot find a piece of evidence — the decision to confirm something as "yes" rests with the company itself, not with the platform and not automatically with whoever does the filling in work.
Why this is not a matter of authority
None of the sources that are relevant here — the EFRAG VSME module, the ten measures of Article 21(2) of the NIS2 Directive, or Annex A of ISO/IEC 27001 — impose any requirement as to the person who fills in a questionnaire. Those regulations are about content: what data a company records, what measures it takes, what control measures it applies. Who processes that administratively in a client's portal is an organisational choice. The same applies to data that are fixed on the basis of the Trade Register Act 2007, such as the statutory name or the registered address: those facts are publicly recorded, but who types them into a questionnaire is not reserved to anyone.
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.