who is internally responsible for sustainability and ESG

Governance question without legally required role

There is no law that prescribes who must lead ESG policy in an SME. The VSME basic module of EFRAG does ask about governance, but sets no requirement regarding a job title, a separate role, or a minimum number of hours. Customer questionnaires often phrase this loosely as "who is responsible for sustainability", and the answer that a procurement or sustainability department expects is a name or role, not a certificate. In practice, responsibility usually lies with the owner, the director, or someone from management who handles it alongside their other duties — and that is a valid answer, provided it is accurate.

What is more often confused: governance questions about ESG are separate from questions about the board itself. If the list also asks about who sits on the board and how it is composed, that is a different answer than who manages the ESG file — at a small company this could be the same person, but the question tests something different. Governance questions often come in a cluster: in addition to who is responsible, the customer also asks about anti-bribery policy and about a reporting procedure. It is therefore useful to have these answers ready together, even if the questions come in separately.

Where this follows from the VSME basic module

The basic module of EFRAG VSME contains a section on practices and governance, which asks whether the undertaking has designated a person responsible for sustainability matters. That is a factual question — who, what role, since when — not an assessment question. The CSRD directive (Directive (EU) 2022/2464) requires larger undertakings to report on governance, but does not impose a direct reporting obligation on SMEs themselves; the VSME is voluntary for smaller suppliers, designed precisely to enable customers that fall under the CSRD to receive a standardised answer. If a customer asks in addition to the ESG person responsible also about a internal whistleblower reporting channel, that falls under a different part of the same governance module, not under the ESG role question itself.