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I have a small team, do I also need to answer personnel questions

Five employees is not an exemption from the personnel module

Yes, personnel policy counts even with five employees. The VSME-basic module makes no distinction by company size within the SME sector: the questions about working conditions, health and safety apply to every organisation that uses the standard, from five to five hundred employees. What does change with a small team is the nature of the answers — not whether you have to give them.

Specifically, it concerns the same fields as in a larger company: whether there is a policy for health and safety at work, whether everyone receives at least the statutory minimum wage, and whether staff are covered by a collective labour agreement. With five employees, "policy" is often not a separate document but a few fixed agreements — that is a valid answer, provided it is factually correct. Where the file has no source for it, such as a formally documented safety policy that simply does not exist, the answer should remain "no", even if that feels unnecessarily strict for a small team.

Basis in Article 1 and 3, no threshold per number of employees

The VSME-basic module of EFRAG is designed as one set of indicators for non-listed SME undertakings without a size threshold within that target group; Directive (EU) 2022/2464 governs the broader reporting obligation to which this standard applies, but voluntary application by smaller suppliers does not itself require a minimum number of employees. If you are unsure whether a specific item — for example the male-female distribution in the workforce — is practically fillable with a team of five, that is a question about how you formulate the answer, not whether you skip the field.

What this is based on

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.

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This 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.