my insurer is also sending a questionnaire on sustainability does the rule apply then too

Yes, the chain provision makes no distinction based on type of counterparty

Yes, this rule also applies if the questionnaire comes from an insurer. The chain provision from the corporate sustainability reporting directive does not look at what kind of company is asking the questions, but at the relationship: a company subject to reporting obligations that needs information from a smaller party in its value chain may not go beyond what the VSME standard permits if that smaller party has 1,000 employees or fewer. An insurer collecting data to prepare its own corporate sustainability report falls under the same provision as a large customer doing so with its suppliers. The question is therefore not "is this my bank, my customer or my insurer", but "is the party asking subject to reporting obligations, and do I fall within the scope that the standard protects".

In practice, this means that a questionnaire from an insurer is to be assessed in exactly the same way as any other: going through each question to check whether the requested information is part of the VSME standard's core module, or whether the insurer is asking for something beyond that scope. What fits within VSME is generally straightforward to answer. What falls outside may be refused — with a clear explanation why. For those who received this specifically from a bank, a comparable explanation is provided at my bank wants me to complete an ESG questionnaire what should I do; the underlying principle, what questions a counterparty is actually permitted to ask, is explained at can my client ask all the sustainability questions he wants.

Why the directive regulates this in this way

This explanation derives from the amendment of March 2026 to the corporate sustainability reporting directive (Directive (EU) 2022/2464), which links the scope of requested information in the value chain to the VSME standard of EFRAG, without limiting the nature of the requesting party to only customers of goods or services.