ESG Questionnaire from a Customer: How to Respond as an SME Supplier

Quick answer. Your customer is asking for an ESG questionnaire, but you're unsure if it's a standard format (VSME, EcoVadis) or a custom request. The first step is to identify the expected format and decide on a single response strategy. The second is to gather your evidence: energy bills, payroll data, certificates, code of conduct, supplier contracts with ESG clauses. Then, you structure a reusable ESG data foundation to answer this request and future ones. Finally, you convert this constraint into a tangible ESG action plan, strengthening your credibility with all partners.

The multiplication of ESG questionnaires responds to three simultaneous regulatory movements.

1. The CSRD directive requires large companies to map their value chain#

Companies subject to the CSRD (directive (EU) 2022/2464) must publish a sustainability report including a map of ESG risks across their value chain. The "Omnibus" simplification package (2025-2026) raised the reporting threshold to 1,000 employees and €450M turnover, reducing the number of directly affected companies. These customers nonetheless continue to collect ESG data from their suppliers to feed this mapping.

2. French due diligence law (2017-399) mandates value chain oversight for large parent companies#

Since March 27, 2017, companies with more than 5,000 employees in France (or 10,000 worldwide) must establish a due diligence plan covering subsidiaries, subcontractors and suppliers. ESG questionnaires become the practical tool to document this oversight.

3. Responsible procurement has become a market standard#

ISO 20400 (responsible procurement) and large groups' sustainable sourcing policies now include an ESG clause. For an SME, ignoring these requests means losing contracts or renewals.

The "Omnibus" simplification package (2025-2026) introduced a decisive safeguard. A large company subject to the CSRD cannot require a partner with fewer than 1,000 employees to provide more information than that set out in the VSME standard. In practice, if a customer sends you a questionnaire that goes beyond the VSME scope, you are entitled to limit your answer to that scope. This rule ends the request inflation seen in 2024-2025 and makes the VSME the reference to favour: report once, serve all your clients.

Before mobilizing your teams, identify the expected format. There are three main types.

Type 1: The VSME standard (voluntary, proportionate)#

The VSME (Voluntary Sustainability Reporting Standard for SMEs) is a voluntary standard published by EFRAG in December 2024 and endorsed by the European Commission in its Recommendation (EU) 2025/1710 of July 30, 2025. It targets SMEs not mandatorily subject to the CSRD and serves as the reference for suppliers with fewer than 1,000 employees (value chain cap).

Type 2: EcoVadis platform (private rating, widely accepted)#

EcoVadis is a private supplier assessment platform. It rates companies out of 100 points across 4 themes (Environment, Social, Ethics, Responsible Procurement). Well-rated companies receive medals (Bronze, Silver, Gold, Platinum).

Type 3: Custom questionnaire (heterogeneous, demanding)#

Some major clients, particularly banks, send tailor-made questionnaires, often lengthy, redundant and without clear standards. This is the most common case for an SME — and the most frustrating.

Strategic advice. If you receive a custom questionnaire, offer your customer to accept a VSME or EcoVadis format response. This reduces your burden and creates a mutual standard.

Before starting, ask your customer or their data provider these three questions.

1. "Is this an official VSME assessment?" → Refer to EFRAG documentation and recommendation 2025/1710.
2. "Do you use the EcoVadis platform?" → If yes, you'll receive a direct invitation; consult the EcoVadis help center.
3. "Do you have a specific questionnaire or written assessment criteria?" → Ask for the document; this helps you prioritize.

Step 1: Map requirements by theme and identify gaps#

Create a three-column table: Domain | Existing data | To develop.

Domains (VSME/EcoVadis):

• Environment: energy bills, water consumption, waste, carbon footprint if available.
• Social: headcount, aggregated payroll data, gender equality index, health-safety incidents, training hours.
• Ethics: code of conduct, anti-corruption policy, GDPR compliance, third-party declarations.
• Responsible Procurement: ESG clauses in supplier contracts, documented audits, sourcing policy.

If an entire category is missing (e.g., no carbon footprint), note it explicitly and plan a follow-up action.

Step 2: Gather documentary evidence#

For each questionnaire question, require proof. Here's the standard accepted by evaluators:

Key point: a documented absence is acceptable ("no carbon footprint yet, will be completed in 2027"). A false claim destroys your credibility.

Step 3: Structure your data in a single ESG reference framework#

Don't answer each questionnaire in isolation. Build a reusable ESG data foundation.

Recommended foundation:

1. ESG identity sheet: scope (single entity or group), average headcount, main sites, sectors.
2. Key indicators dashboard: energy (kWh/year), scope 1 & 2 emissions (tonnes CO2e), headcount, training hours, accidents, turnover.
3. Policy matrix: list of formal policies in place (HR, ethics, environment, procurement, diversity).
4. Evidence inventory: centralized list of documents justifying each policy (date, responsible person, file link).

This foundation can be completed in 2-4 weeks and reused for multiple questionnaires.

Step 4: Complete the questionnaire with consistency and honesty#

Golden rules:

• Provide detailed answers: vague responses score poorly.
• Systematically attach requested evidence: certificates, contracts, invoices, registers.
• Be honest about gaps: "We don't have a carbon footprint yet in 2026, but we've budgeted an external study for 2027."
• Align your answers with documents: inconsistency between a statement and an attachment undermines credibility.
• Avoid empty marketing speak: "We are committed to the environment" doesn't replace data.

Step 5: Convert the response into an annual CSR action plan#

Once the questionnaire is submitted, don't close the file. Use it to improve your ESG standing.

1. Analyze gaps: what topics scored poorly or lack evidence?
2. Set objectives: e.g., "obtain a certified carbon footprint by June 2027", "increase female management representation to 35% by 2027".
3. Budget accordingly: these actions cost money; plan for them.
4. Communicate internally: your teams must understand that credible ESG requires real change, not just verbal responses.

Supplier to a CSRD-mandated large group. Your customer must map its value chain per CSRD. A VSME Basic response often suffices for a first cycle.

Industrial sub-contractor SME at Tier 1 level. Your customers (themselves suppliers to large groups) will ask for certified data. Invest in a carbon footprint and ISO certification if your sector requires it (14001, 45001).

Multi-site or complex structures. Clarify expected scope: single entity or consolidation? A group may need to respond on different scopes depending on customers.

SME with one major client. If 80% of revenue comes from a customer demanding EcoVadis, treat it as a major investment. A Silver medal strengthens your position to negotiate more favourable contractual terms.

• The number of ESG questionnaires is rising: some SMEs now receive 3-4 per year, often overlapping. Impose a single standard when possible.
• Customers verify inconsistencies: EcoVadis evaluators, for example, cross-check your answers against public data (business register, press, litigation).
• Data evolves quickly: an EcoVadis score obtained at date A may need updating without equivalent.
• Confidentiality is relative: only you see the detailed report, but your customer sees your score/medal and may request it annually.
• Cost is not neutral: a first EcoVadis assessment represents budget + internal resources; a DIY VSME response costs less but requires more rigor.

Since 2025, the flow of ESG questionnaires our SME clients receive has intensified. As a certified accountant registered with the Order, we assist these suppliers in two phases: initial response (data collection, file assembly) and conversion into a sustainable action plan.

Recently, an 80-person industrial sub-contractor received an EcoVadis request from its primary customer (prerequisite for a three-year contract). Without support, the company would have sent a fragmented file. Our initial diagnosis revealed environmental data scattered across three locations, inconsistent social data (non-historicized payroll), and undocumented ethics (no formal code of conduct). In 12 weeks, we consolidated the VSME Basic foundation, supplemented with missing EcoVadis disclosures. The assessment returned a score of 62/100 with a Bronze medal. Most importantly, the customer obtained the visibility it sought, and the company now has a reusable ESG framework.

Hayot Expertise advice. Treat an ESG questionnaire not as a one-off administrative burden, but as the entry point to a structured ESG initiative. This begins with a simple diagnosis: where do you stand on the 4 themes (environment, social, ethics, procurement)? An honest answer to this question lets you prioritize effort and avoid false promises. At Hayot Expertise, we help SMEs and mid-caps identify the expected format, gather evidence and build a credible action plan. Explore our complete CSR and CSRD reporting support and our digital transformation expertise to strengthen data collection reliability.