why does the bank want to know how many employees I have
Employee count determines your customer's CSRD regime
The bank usually does not ask this to qualify your business, but to determine itself under which reporting regime your customer falls and what chain data is required for that. The number of employees is, together with turnover and total balance sheet, one of the threshold values from Directive (EU) 2022/2464 (CSRD) that determine whether an undertaking is itself subject to reporting obligations, and at what level of detail. For the bank as a financial institution, your employee count counts towards the chain information it needs to compile its own sustainability reporting, even if you are not yourself subject to CSRD obligations.
Additionally, banks often use the number of employees as a scaling indicator in the EFRAG VSME basic module, the voluntary standard specifically designed for non-listed SME undertakings. If you complete that list for the first time, the answer is usually simply your current FTE number; an explanation of part-time or seasonal work is rarely requested, but some portals have a separate field for that. Note the difference with the number of countries where you have establishments: banks often ask those two in the same list, because together with employee count and turnover, geographic distribution also counts in determining the risk profile.
Where that comes from: threshold values and register data
The link between employee count and reporting obligation follows from the size criteria of Directive (EU) 2022/2464 (CSRD); the VSME basic module of EFRAG develops the same indicator for SME undertakings that are not themselves subject to that directive. The registered number of employees as recorded in the business register is established under the Trade Register Act 2007 — if in doubt about what counts as "current", that is the link that most banks expect, just as with the turnover requested as basic data.
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.