am I as a small business required to complete this questionnaire
It is usually not mandatory, but neither is it entirely optional
No, a small business is in most cases not legally obliged to complete this list. The CSRD (Directive (EU) 2022/2464) imposes reporting obligations on large and listed undertakings, not on SMEs. If the list you have received is based on EFRAG's VSME standard, that is precisely what the name says: voluntary ("Voluntary"), intended for unlisted SME undertakings that are asked for information by a larger customer.
Completing it voluntarily does not mean it is without consequences for the relationship. Your customer is probably asking for the list because they themselves fall under the CSRD and need to map their supply chain. Refusing may then affect the commercial relationship, even without a legal obligation. What you usually do have on hand in the VSME basic module are the factual data: the number of employees and the countries where you have establishments are usually already in your own records and are not a matter of contention. Where things more often get stuck are qualitative questions about policies or objectives that you have not yet formalised — there you can factually answer "no, not yet" or "in development", without this being scored or assessed anywhere.
Basis: CSRD scope versus VSME voluntariness
The distinction follows directly from the scope provisions of Directive (EU) 2022/2464, which links the reporting obligation to size criteria that a small business typically does not meet, and from the status of the VSME itself as a voluntary framework from EFRAG for undertakings that fall outside that scope but are nonetheless asked for information by chain partners. Note: this is separate from obligations that may directly apply to you, such as the basic registration under the Trade Register Act 2007 or, in another list, the ten measures of Article 21(2) NIS2 — the latter concerns cybersecurity rather than sustainability.
What this is based on
- Trade Register Act 2007 — the data recorded for each company
- EFRAG VSME — the voluntary standard for non-listed SMEs, basic module
- Directive (EU) 2022/2464 (CSRD)
- ISO/IEC 27001 — Annex A, the control measures
- Directive (EU) 2022/2555 (NIS2), Article 21(2) — the ten measures
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis 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.