how diverse is my management or board, what do I enter for the list
Diversity is about the ratio of men to women and about independent members
Most questionnaires ask two things: the percentage of women and men in the highest governing body, and whether there are independent members. Under VSME basic module B10 you report the number of members of your governing body by gender, and optionally the proportion of independent members. This is a count, not an assessment — there is no minimum percentage you need to reach to score "well". You enter what is factually the case: how many men, how many women, and how many members without an executive role or family ties to the company.
If you have one manager or a small team of two or three, then "diverse" often does not apply in the sense the questionnaire intends — simply enter the factual number and distribution, without exaggerating or apologising for it. Note the difference between a question about the composition of the board as a whole: that question often goes broader, about who is in it and how those people were appointed, whereas the diversity question specifically asks about the gender and independence distribution. If you confuse this with a question about who is on your board and how it is composed, first check which of the two your client actually means — it will save you a duplicate entry exercise. If you do not have a permanent governing body, for example in a sole proprietorship or partnership, the answer is usually "not applicable", and you may write it that way too.
Where that is stated in the VSME standard: module B10
The obligation to report this does not come from the law, but from a voluntary standard: EFRAG VSME, module B10, intended for non-listed SMEs that are asked by a larger client for sustainability information. This standard is an elaboration of the supply chain information need that follows from Directive (EU) 2022/2464 (CSRD): large companies must report on their entire value chain and pass this requirement on to their suppliers via questionnaires. As a supplier, you are usually not CSRD-obligated yourself; you only provide the requested data. If your company also has a procedure for conflicts of interest within the board, this sometimes affects the same questionnaire — in that case also check the question about a procedure for conflicts of interest, because clients often combine board composition and integrity policies in one section.
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.