why does the insurer need my number of employees

Number of employees is a risk and premium variable, not a CSRD question

The insurer asks for the number of employees because this is a direct indicator of the risk they are insuring. For liability insurance or a cyber policy, the size of the workforce helps determine the extent of exposure: more employees means more actions, more access to systems, greater chance of an error or incident. This is separate from sustainability reporting — it is an underwriting and premium question, not a CSRD or VSME question, even if the figure resembles what you enter there as well.

Origin and evidence are straightforward here: the number of employees is a factual figure that you determine yourself, not something that is attested by a third party. Insurers sometimes ask for a reference date or an average over the year; if the policy questionnaire does not specify that, the standard answer is the current number at the time of completion. If you are unsure whether the insurer means FTEs or headcount, the answer is usually acceptable as long as you state in the explanation which counting method you are using — this prevents disputes later when making a claim. For the underlying composition of this figure in your chain file, see how many employees does the company have.

Where this is separate from statutory reporting obligations

The number of employees has no separate statutory basis like, for example, the trade register number, which follows directly from the Trade Register Act 2007. The figure does appear in several contexts with different counting rules: the EFRAG VSME basic module for SME reporting, the ten measures of Article 21(2) of the NIS2 Directive (where company size determines whether the directive applies), and now also the insurance questionnaire. It is therefore advisable to check per questionnaire which counting method is requested, even if the figure itself remains the same. Insurers often combine the number of employees with other risk indicators, such as whether the company is ISO 9001-certified, in order to obtain a more complete risk picture.