ESG questionnaire from your largest customer: what do you really need to fill in?

## The question now coming to many SMEs Your largest customer, your bank or your insurer sends a list with dozens of sustainability questions and expects it back within a few weeks. You are not a lawyer, you do not have a sustainability department, and the question that remains is simple: what do you actually have to fill in here? The answer has been fixed since March 2026 in an amendment to the corporate sustainability reporting directive, the so-called chain requirement. It determines that a company which is itself obliged to report may not ask a supplier with one thousand employees or fewer for more sustainability information than is contained in the voluntary EU standard for non-listed SMEs, the VSME. Anything beyond that, you as a supplier may refuse. The rest of this article shows you how to make that distinction in practice. ## Why this limit was introduced Before this requirement applied, every buyer in the chain could essentially draw up their own list, often based on the extensive reporting standard for large, listed companies. For an installation company or an office business with twenty or fifty employees, that is a different order of magnitude than the standard for which that standard was written. The chain requirement thus links the question to a standard that was specifically created for smaller companies, so that the scope of what is asked is proportionate to the size of the company that answers. The VSME itself is not an obligation in itself. It is a voluntary framework that gets a limit once a reporting-obliged buyer asks for it. Anyone not yet familiar with the standard can find [[LINK:/onderwerpen|an overview of what is contained in it and what is not, examined per subject]]. ## How to recognise a question that falls within the limit Questions about energy consumption, your main emission sources, the number of employees and basic data on working conditions usually come up again in the VSME and thus usually fall within what may be asked. Questions that often go further than the standard are, for example, detailed scope 3 chain analyses of your own suppliers, extensive biodiversity reports, or a full due diligence policy as large companies must conduct. Whether a specific question in your case falls within the VSME or not is something that must be assessed per question against the text of the standard itself; supervisors and the official text on EUR-Lex are the starting point, not a general impression. ## How to refuse the excess neatly Refusing a question need not become a conflict. It helps to separate three things: what you do provide, why the rest falls outside the standard, and that you are open to clarification if the buyer thinks it falls under the VSME anyway. A wording that often works refers to the chain requirement itself and to the fact that your company falls below the threshold of one thousand employees, without putting the relationship on edge. Buyers are receiving this question from many suppliers at the moment and expect a clear, substantiated answer sooner than an extensive legal justification. ## What remains, and where the file begins The questions that do fall within the VSME, you still have to answer, and that is usually most of the work. Many of those answers are already in documents you have: an energy bill, fuel receipts, a printout from your payroll administration. Assessing which question falls within the limit can be free: the capcheck on esgia.eu does that per question, without an account. It is a first, practical step to see how large the remaining list actually is. If you want to see in a few minutes where your company roughly stands, the [[LINK:/quick-scan|quick-scan with a few questions provides a first indication]]. It is good to keep clear what such an assessment is and is not. A capcheck or a filled-in questionnaire is not legal advice, not an audit and not a keurmerk; for this type of SME reporting, there is currently no recognised body, with no provider. If you are in doubt about a specific situation, for example when the number of employees is around the threshold of one thousand or when a buyer motivates a question differently, it makes sense to discuss this with a lawyer or with the competent supervisor. More about how the assessments are made and what sources underlie them is described on [[LINK:/hoe-het-werkt|the page that explains where the information comes from]]. ## If the standard itself changes The VSME and the chain requirement are now fixed, but not static: interpretations are sharpened and thresholds can be clarified. Once you have built up a file, you do not want to figure out every time whether a change is relevant. Questions that come up more often about how this works exactly are collected on [[LINK:/veelgestelde-vragen|the page with frequently asked questions]]. Do you first want to see how much of the list you received actually falls within the limit? Do the free quick-scan or browse through the topics; both cost no account and provide an immediate concrete starting point.