do I need to count self-employed workers in personnel questions

Self-employed contractors are usually separate from your headcount

No, in most VSME questionnaires you do not count hired self-employed contractors in your regular personnel figures. The basic module of EFRAG VSME asks for the number of employees ("employees"), and that is a labour law concept: someone with an employment contract. A self-employed contractor provides services on the basis of a service agreement, not an employment contract. For headcount, the male-female distribution and training hours, the self-employed contractor therefore remains outside the scope — those questions concern your own personnel, not hired capacity.

That does not mean self-employed contractors do not appear anywhere in the questionnaire. Some clients ask separately about the composition of the "workforce" in a broader sense, including hired staff and temporary workers, especially when it comes to working conditions or health and safety further down the chain. So check each question to see whether it specifically says "employees" or "employees", or whether a broader concept such as "workforce" is used. If in doubt about what a client means by a specific personnel question, it is useful to look at what does your client mean by the male-female distribution within the personnel — the same distinction between employees and broader hired personnel is explained there.

Basis in the definitions of the VSME standard

This distinction follows from the definition provisions in the basic module of EFRAG VSME, where "number of employees" is linked to an employment contract, in line with the broader system of Directive (EU) 2022/2464. For questions that do concern the broader chain — for example working conditions for hired personnel — it is advisable to look at how you answer questions about working conditions further in your chain, because the scope is slightly different there than for pure personnel figures.