do we need to have an official sustainability policy in writing

No, VSME does not request a document, but it does require documented figures

No, a written sustainability policy is not mandatory for the VSME basic module. The basic module requests quantitative data: energy consumption, emissions within own scopes, water consumption, waste, and a number of figures on personnel. There is no separate field that requests a policy document with a date and signature from management. Anyone receiving the list for the first time who does not have a written policy can, in many cases, still provide a complete answer, as long as the figures themselves are substantiated.

Where it does become difficult: some customer portals add their own questions on top of the VSME basic questions, which come from the comprehensive module or from their own ESG questionnaire, and sometimes there is a question about a formally established policy. That is then a requirement of that specific customer, not of the VSME standard itself. Check per question whether "policy" or "figures" is being requested — this distinction determines whether "no, not yet" is a problem or not. This question often appears in the same section as questions about integrity, and a similar logic applies there: when the question of whether a policy against bribery and corruption exists a distinction is also made between "policy on paper" and "practice without a document".

Where this distinction in the standard comes from

This distinction follows from the structure of the EFRAG VSME: the basic module (Basic Module) is deliberately limited to quantitative, directly measurable data, while policy statements and explanatory texts are in the comprehensive module (Comprehensive Module). Directive (EU) 2022/2464, the CSRD, is the reason large customers collect this data from their suppliers, but it does not itself impose a policy obligation on SMEs. For questions on governance topics that often appear in the same questionnaire, such as the question of an internal reporting channel for whistleblowers, the same rule of thumb applies: first check whether the question is asking for a figure, a yes/no, or a document, before you determine what you need to provide.