my client does not accept that I refuse to answer a question

A customer may reject a refusal, but cannot set aside the VSME threshold

If a customer does not accept that a question remains unanswered, that does not change the underlying principle itself: the value chain provision in the sustainability reporting directive draws a line at what a reporting-obligated company may ask of a supplier with one thousand employees or fewer. Disagreement over that line is primarily a matter for discussion between two parties, not an automatic vindication for whoever drafted the questionnaire. A customer may well insist that the information is necessary, may ask for an explanation, or may call the relationship into question on other grounds — that is a business decision, separate from the question of whether the original question fell within the VSME scope.

In practice, it helps to keep the discussion as factual as possible: not "I don't have to say this", but a reference to the standard on which the refusal is based, with a brief, business-like explanation of why the requested information falls outside it. What such a formulation looks like is set out in how do I politely write that I will not answer a question. If the customer persists, the underlying issue is often not the tone of the answer but whether the question asked truly exceeds the VSME basic module — that is precisely what can my client ask all the sustainability questions he wants addresses.

What this rests on: the value chain provision and the VSME basic module

The value chain provision in Directive (EU) 2022/2464 limits what a reporting-obligated company may require of a smaller supplier, using the VSME basic module of EFRAG as the reference point for what falls within it. This limitation governs what may be asked — not how a customer responds if a supplier invokes it, and not what happens if the parties disagree. For the latter, in the case of these SME reports, there is no recognised body that makes a determination.