do we have independent board members question to fill in
Independence is usually only relevant to a supervisory board
For most SME structures with only a management board or board of directors, this question is straightforward to answer with "no" or "not applicable": without a supervisory board or separate overseers, there is nothing to test for independence. The question comes from the governance module of questionnaires and concerns whether there are directors or overseers without business or personal ties to the enterprise, management or shareholders — so no family, no supplier, no (former) employee.
If the enterprise does have a supervisory board or advisory board, the answer is only "yes" if you can demonstrate who holds that independent position and why. Supporting documentation is usually a list of the board with function, appointment date and a statement of independence, or simply the absence of a business relationship in the records. If you do not have that overview readily available, then "no" with an explanation ("no supervisory board") is the safest answer — a "yes" without underlying documentation cannot be justified once the client asks for it. This question is often in the same section as the question about who is on the board and how it is composed; it is efficient to answer both at the same time from the same source.
Where this comes from: the governance indicators of VSME
The question about independent board members does not come from a law, but from the voluntary VSME standard of EFRAG, the basic module for non-listed SME enterprises that banks and large clients use as the basis for their own sustainability questionnaires under the CSRD Directive (Directive (EU) 2022/2464). Because VSME is a voluntary framework, there is no legal threshold or percentage — the standard of "independent" is filled in by the client themselves for each questionnaire, so always read the explanation of the question in the client's portal. If that explanation is missing, it is advisable to use the standard definition: no business or family ties with management or shareholders. If there is also a question about a reporting procedure in the same list, then the explanation of the whistleblower procedure question helps to complete that governance section in one go.
What this is based on
- EFRAG VSME — the voluntary standard for non-listed SMEs, basic module
- Act on the prevention of money laundering and the financing of terrorism — client due diligence
- Directive (EU) 2022/2464 (CSRD)
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.