can my client ask all the sustainability questions he wants

No, that has been limited since March 2026

No, not just anything. Since March 2026, the following applies: when a reporting company requests sustainability information from a supplier with one thousand employees or fewer, it may not exceed what is stated in the VSME standard — the voluntary EU standard specifically developed for unlisted SMEs. This limit is called the value chain provision, and in practice it works like a ceiling: the buyer may want to map its own value chain, but may not go beyond that ceiling when the supplier falls within that employee threshold.

That does not mean every question that goes beyond the VSME standard is unjustified — sometimes a question is formulated slightly differently but is nonetheless covered by the standard. And the limit applies specifically to the scope of what may be requested, not to the way a bank or insurer formulates its own questionnaire; they may have other reasons for asking what they ask, and different considerations apply to that — see my bank wants me to complete an ESG questionnaire what should I do and my insurer is also sending a questionnaire on sustainability does the rule apply then too. What is clear is that a question falling outside the VSME standard can be refused — with an appropriate response, not with a blunt rejection.

Where this follows from the directive and the VSME standard

The reporting obligation itself comes from the sustainability reporting directive (CSRD, Directive (EU) 2022/2464), which establishes which companies must report and — since the amendment of March 2026 — how far they may burden their smaller suppliers in doing so. The substantive limit is the VSME standard from EFRAG: it sets out which topics and indicators a non-listed SME can reasonably provide, from energy consumption to the classification of emissions into scope 1, 2 and 3 according to the GHG Protocol. Anyone wanting to see whether a specific question falls within that limit can have that question assessed: what exactly is esgia's capcheck explains how that assessment works for each question, and what is VSME and what does it have to do with me shows what is contained in that standard.