what are the consequences if I don't complete the ESG questionnaire
No legal penalty, but a real commercial consequence
Not filling in anything usually does not result in a fine — the ESG questionnaire that your customer sends is generally not a legal obligation for you, but rather the way your customer completes his own CSRD reporting (Directive (EU) 2022/2464). The supply chain information that your customer needs must come from somewhere, and if you do not provide it, he must estimate or ask. That is not a fine for you, but it is a risk: in a tender or contract renewal, an empty or late list can carry more weight than a substantively meager response.
In practice, you see three routes if you do not fill in anything. The customer asks again, often with a deadline shorter than the original. Or the customer fills in an estimate himself — usually a conservative one, so unfavorable for you. Or the contract simply does not come about, without anyone explicitly saying so. Filling in a list halfway — only the fixed basic data such as the number of employees and the countries where the company has establishments — is virtually always better than nothing, because it already saves the customer from having to request that information separately.
Legal basis: CSRD obliges the customer, not the supplier
The CSRD (Directive (EU) 2022/2464) places the reporting obligation on the undertaking falling within the scope of the directive, not on its suppliers. For SMEs, there is no legal ESG reporting obligation; the EFRAG VSME standard is explicitly voluntary and designed to structure precisely this kind of supply chain questions, so that an SME supplier does not have to fill in a different format for each customer. The consequence of not filling in therefore does not run through a law that affects you, but through the contract or procurement terms of your customer — and you will only find those in the correspondence or agreement with that customer itself, not in the CSRD.
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.