do I have to provide ESG figures per location or for the entire company

Group level is the standard, location detail is the exception

Most ESG questionnaires request figures at the level of the reporting undertaking as a whole, not per location. EFRAG's VSME basic module is structured around the undertaking as registered in the business register, with its total number of employees and total turnover — thus consolidated, not broken down by site. If your customer does ask per location, this is usually an additional requirement from that specific customer, not a standard component of the basic module.

Where things often go wrong: as soon as an undertaking has locations in multiple countries, some customers still want to see a breakdown, for example for CO2 emissions per location or for working conditions per country. This is then an extra question alongside the basic figures, not a replacement for them. If you don't have that breakdown readily available, the most honest answer is that you report at group level and do not separately maintain location details — fill that in accordingly, rather than presenting an estimate as a measured figure. Also relevant here is in which countries the enterprise has establishments, as that question often appears in the same section as the figures.

Basis in the VSME module and the underlying CSRD

EFRAG's VSME standard is written for non-listed SMEs and is based on reporting at undertaking level, aligned with the data already established under the Business Register Act 2007 — the same source from which the registration number and the number of employees also come. The VSME is intended as a proportionate response to the wave of questionnaires arising from Directive (EU) 2022/2464 (CSRD): large undertakings must map their supply chain and translate that into questionnaires to their suppliers, but the CSRD itself does not require SMEs to report at location level. A breakdown per location is therefore not in the basic module, but can be added as an extra requirement by an individual customer.