why do I as a small business have to answer sustainability questions for a large customer
Your customer is passing the CSRD obligation on to you
Your customer is usually asking this because they themselves fall under the CSRD, Directive (EU) 2022/2464, and are obliged to report on their entire value chain — including suppliers like you. As a small business, you yourself remain outside the direct reporting obligation, but that information still needs to come from somewhere. Your customer often uses a questionnaire derived from the EFRAG VSME, the voluntary standard specifically created for non-listed SMEs to keep the questions manageable.
The questions themselves usually cover three clusters: basic company data, energy and emission figures, and policies on working conditions and governance. For the first cluster — what the registered name of the company is and in which countries the enterprise has establishments — you usually already have a source in the value chain file. For emission figures, that is more difficult: if you do not maintain CO₂ accounting, the most honest answer is that you do not have that data now, rather than an estimate that you cannot substantiate.
VSME module and CSRD chain obligation
The basis lies in two documents that connect with each other. Directive (EU) 2022/2464 requires large, listed companies to report on their chain, and that obligation extends to suppliers as soon as the customer requests substantiation. The EFRAG VSME is not a legal requirement but a format: it was designed to prevent each major customer from sending its own list with slightly different questions to SMEs. This also explains why questionnaires from different customers are often very similar in structure, even though they come through different portals.
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.