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does the list ask about management remuneration, do I need to fill that in

Remuneration ratio between management and average employee, not the amount itself

Usually not as a separate, traceable amount. The VSME basic module does not ask for board compensation as such in the governance section, but rather for the ratio between the highest compensation and the average or median compensation within the undertaking — often expressed as a ratio (for example 8:1). This is different from "what does the director earn", and that distinction is precisely what you want to maintain in your answer: you provide a ratio figure, not a payslip.

If the list specifically addresses "board remuneration" or "compensation of key management", first check whether it is asking for the amount itself or for that ratio — listed-company clients with a group questionnaire sometimes copy CSRD items through to their SME suppliers, whereas the mandatory reporting on this under the directive does not apply to you as an unlisted undertaking. If you do not have the ratio at hand, then "to be determined" is the honest answer here until your payroll administration has provided the figure — do not fill in an educated guess. This issue is often linked to questions about the composition of your board, because clients often combine board and remuneration in one governance section.

Where that is stated in the VSME base module

The basic module of EFRAG VSME treats board information as part of the general company data, and the remuneration ratio is a separate, optionally positioned data point within it alongside matters such as board composition and diversity — not alongside the financial figures. If the same questionnaire also asks for a corruption or conflict-of-interest declaration, this concerns a different part of the standard; check then what your client specifically means by an anti-corruption policy before you use the same chain file for two different questions. The client due diligence under the Anti-Money Laundering and Counter-Terrorist Financing Directive is not relevant here: it concerns the identification of ultimate beneficial owners, not the remuneration structure.

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.