An email from your customer's procurement team: a sustainability questionnaire, a spreadsheet attached, a deadline, and the words "VSME", "CSRD", or "supply chain ESG data".
This is happening to suppliers across Europe, and the reason is straightforward. Before opening the spreadsheet, establish what it is and what it needs.
| First question | Short answer |
|---|---|
| Why did they send it? | Your customer reports on its value chain, under CSRD or to its own customers and lenders, and needs supplier data to do it. |
| What is VSME? | The EU's simplified sustainability reporting standard for SMEs. Adopted as EU law in July 2026. Voluntary for companies outside CSRD scope. |
| How much is it? | Eleven disclosures. Most of the data is in utility bills, payroll, waste invoices, and HR files. |
| What if I do not have everything? | Send what you have, estimate where necessary, state the method, and say what will improve. |
| What if I do not respond? | Follow-ups, then a non-responsive flag, then a disadvantage in supplier evaluation. |
Why this is happening now
Your customer may be subject to the EU's Corporate Sustainability Reporting Directive, or answering its own customers, lenders, or procurement rules. Where CSRD applies, it requires large companies to publish detailed sustainability reports covering their entire value chain, suppliers included.
CSRD began phasing in from 2024. The 2026 Omnibus reform narrowed it: mandatory reporting now applies only to companies over 1,000 employees and €450 million turnover, phasing in from financial year 2027. If your customer is in scope, they cannot complete their report without data from suppliers.
CSRD requires them to report on:
- Scope 3 emissions — the carbon footprint of their supply chain. Your energy use and emissions are part of their figure.
- Supply chain labor practice — how suppliers treat workers. Your workforce data, safety record, and employment practice.
- Supplier governance — whether supply chain partners operate ethically. Your anti-corruption, data protection, and compliance policies.
- Environmental impact — water, waste, pollution across the value chain. Your operational data.
They are collecting because they must report.
What VSME is
The Voluntary Sustainability Reporting Standard for SMEs was developed by EFRAG (the European Financial Reporting Advisory Group), endorsed by the European Commission as a recommendation in July 2025, and adopted as a delegated act — EU law — in July 2026. It is the recognized standard for the sustainability data large companies request from suppliers. Using it stays voluntary for companies outside CSRD scope.
VSME exists because asking a 50-person supplier for the same 200-page report as a multinational is not proportionate. It defines a simplified set of disclosures SMEs can report, giving large companies the data they need without burying smaller suppliers.
"Voluntary" means no fine. When the customer's questionnaire is VSME-aligned, not responding has commercial consequences rather than legal ones.
For the VSME versus CSRD distinction, see the comparison guide.
What they are asking for
Most VSME-aligned supplier questionnaires cover the 11 Basic Module disclosures.
B1 — about your company. What you do, where you operate, how many employees. Information you already have.
B2 — governance. Code of conduct; policies on anti-corruption, data protection, environmental management; who oversees sustainability. List what exists. State what does not.
B3 — energy and emissions. Electricity (kWh per year), gas (kWh per year), vehicle fuel (liters per year), Scope 1 emissions (gas and fuel burned), Scope 2 emissions (electricity bought), renewable share. The most data-intensive section. Sources: utility bills and fuel receipts.
B4 — pollution. Significant air, water, or soil pollution. For many service and light-manufacturing companies, "Our operations do not generate significant pollution" is an honest and complete answer.
B5 — biodiversity. Whether operations affect protected areas or sensitive habitats. For most suppliers, a short statement about site locations.
B6 — water. Total consumption in cubic meters per year. One number, from the water bill.
B7 — resource use, circular economy and waste. Total waste (metric tons per year), recycling rate, hazardous waste if any. From hauler invoices or reports.
B8 — workforce, general. Headcount (FTE), gender split, hires and departures. From payroll or HR.
B9 — workforce, health and safety. Accidents, injuries, fatalities; hours worked for rates. From incident records and HR.
B10 — workforce, remuneration, collective bargaining and training. Training hours, total and per employee; collective bargaining coverage. From training and HR records.
B11 — convictions and fines for corruption and bribery. Any during the period. For most suppliers, "none", but it must be stated.
Eleven disclosures. Most of the data is in records you already hold.
How to respond
Two or more weeks before the deadline
Week 1 — collect
- Utility bills for the last twelve months (electricity, gas, water)
- Fuel receipts or fleet records for the same period
- A waste summary from your waste contractor
- Headcount from payroll (FTE, gender split)
- Workplace incidents and training hours from HR
- A list of existing policies and certifications
Week 2 — calculate and respond
- Sum the annual consumption figures
- Calculate emissions with standard conversion factors, or with a tool
- Fill in the questionnaire from the collected data
- Write brief, honest answers to narrative questions
- Check for consistency; submit
Less than two weeks
Use what is immediately available: recent utility bills, current headcount, incident records. Estimate where necessary and state the method. A response with some estimated figures is better than no response. Most customers accept a first response with gaps if you indicate that data quality will improve.
Already tracking
If ESG data has been collected monthly, the questionnaire is a mapping exercise: energy, emissions, water, waste, and workforce data are already compiled.
If you do not respond
Short term. The customer follows up, possibly several times. Their procurement team has its own deadline and your missing data blocks it.
Medium term. The customer may flag you as non-responsive. Some companies have policies to deprioritize or phase out suppliers who cannot provide basic ESG data.
Long term. As CSRD matures and more companies need supply chain data, providing ESG information becomes a baseline expectation, like holding insurance or meeting quality standards. Procurement teams at major European companies are already building ESG criteria into supplier evaluation and tenders.
Preparing for the next one
The first questionnaire is the hardest because everything is built from scratch.
- Track monthly. Electricity, gas, water, waste, headcount, entered once a month. The next questionnaire then has twelve months of data behind it.
- Save your answers. The core questions repeat. Adapt rather than rewrite.
- Organize around the 11 VSME disclosures. Any VSME-aligned questionnaire is then covered, and most non-VSME questionnaires ask the same topics.
- Keep the data in one place. ESG Passport tracks VSME-aligned data in the browser, calculates emissions, and generates questionnaire responses. The free tier covers tracking; the paid version (€499 one-time) adds the response generator and document extraction from bills and invoices.
For each disclosure in detail, see the VSME reporting guide. To check where you stand now, the free VSME readiness tool shows which disclosures you can already cover.