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what do I fill in if I don't know the answer to an ESG question

Not filling in an answer is also an answer

If the answer to an ESG question is missing, the most honest entry is usually "not known" or "not applicable" — not a guessed yes or no. A customer questionnaire often asks for figures or measures that have not yet been established internally: the proportion of women in management, the CO2 emissions of purchased services, a whistleblower scheme that does not yet exist. For non-listed SMEs, the VSME-basic module of EFRAG exists for this purpose, and that module itself makes a distinction between what you know, what you do (not yet) measure, and what is simply not applicable to your business. You may apply that distinction in your answer.

What does not help is filling in an estimate that you cannot substantiate. A customer who asks about scope 3 emissions and receives a figure without explanation can come back to it later — and then "I wasn't sure" is a more difficult answer than "I indicated at the time that I don't measure it". For most questions that go beyond the basic company data, such as in which countries the enterprise has establishments or or whether AI systems are deployed within the service provision, the same rule applies: an empty field with a brief explanation is better than a filled field without a source.

Where that distinction in the VSME-basic module comes from

The VSME-basic module of EFRAG is set up as a light reporting standard for SMEs that are not subject to the full CSRD obligation (Directive (EU) 2022/2464), and that module explicitly builds on what a company can reasonably be expected to know. It therefore distinguishes between core indicators that virtually every company can fill in — such as energy consumption or staff data — and indicators that require more measurement work, where "not measured" is a foreseen outcome and not an error.

What you concretely need to do

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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.