asks customer to clarify board composition in questionnaire

Board composition: usually roles and independence, not names

Yes, this question recurs in almost every ESG questionnaire, and usually it concerns the structure, not a list of names. What is typically asked: how many board members or executives are there, what roles are there (executive/non-executive), and sometimes whether there are independent members or how diverse the composition is in terms of background or gender. For an SME with a single director-owner, the answer is often straightforward: one board member, no separate supervisory board. That is not a problem, that is simply the structure of the enterprise.

The point is where the answer comes from. If there is no current chain file with the current board structure, there is also no source to mark "yes, explained" for. Fill this in based on what is actually documented: the articles of association, the Trade Register, or your own overview of functions. Some clients also ask about it in combination with questions about who sits on the board of directors and how it is composed — that is the same question, just slightly more specifically formulated. If oversight of integrity is part of the question, it often also comes up whether there is a procedure for reporting conflicts of interest, especially for board members with multiple functions.

Basis in the VSME module, not in legislation

This question does not appear in a law that applies to SMEs, but comes from the voluntary reporting standard of EFRAG for non-listed enterprises (VSME), basic module, under the indicators on governance and management. Larger clients who themselves report under the CSRD Directive (Directive (EU) 2022/2464) often translate those governance requirements to their own suppliers, even if those themselves are not CSRD-obligated — which is why the question appears in portals of companies that do have to report. There is no legal obligation for SMEs to report this; it is the client asking for it, not the authorities.