do I as a small business have to complete a sustainability questionnaire

No, VSME is not an obligation

No, the VSME list is not a legal obligation. VSME stands for Voluntary SME — the voluntary standard that EFRAG has developed for unlisted SMEs. The name says it all: voluntary. There is no law that forces a small company to complete this basic module. The directive that makes sustainability reporting mandatory, Directive (EU) 2022/2464 (CSRD), imposes that obligation on large enterprises and listed companies — not on SMEs themselves.

What does happen: a large customer who themselves report under the CSRD must obtain data about their supply chain, and often uses the VSME questionnaire for this because it exists as a standardised format. This is how a small company ends up with the list on their desk — not because the law requires it, but because the customer asks for it. You can then decide to complete it to maintain the relationship, or determine that you don't (yet) supply certain parts. This is a commercial decision, not a legal obligation. With the basic questions about the company itself — how many employees the enterprise has and what the annual turnover is — it is often data you have already recorded elsewhere, so it takes little extra effort.

Where this difference in legislation comes from

The distinction between mandatory and voluntary follows directly from the scope of Directive (EU) 2022/2464: that directive specifies the categories of enterprises that fall under the reporting obligation, and EFRAG's VSME basic module is explicitly designed outside that circle — as a tool for SMEs that are asked for information by their supply chain, not as a binding standard for them. If you are unsure whether your company does fall under the CSRD itself, that can be assessed against the thresholds in that directive, regardless of whether a customer asks for a VSME list.