Legal SMEs: How to Prepare for Client CSRD Questions

Across Europe, corporate clients are turning to their law firms for sustainability data. Under the Corporate Sustainability Reporting Directive (CSRD), large companies must disclose detailed information about their environmental, social, and governance (ESG) performance — and that includes their supply chain, which often features external legal advisers.

For small and medium-sized legal practices, this means being ready to answer client questionnaires about carbon emissions, workforce diversity, ethics, and governance.

This guide helps legal SMEs prepare for these CSRD-related requests using simple, proportionate methods based on the Voluntary Sustainability Reporting Standard for SMEs (VSME). For a comprehensive overview, see the CSRD guide for law firms and accounting practices.

1. Why Clients Are Asking for Sustainability Information

From 2025 onwards, large companies and listed entities across the EU must publish sustainability reports under the CSRD. These reports cover:

• Environmental impacts (energy, waste, emissions)
• Social aspects (workforce, diversity, wellbeing)
• Governance (ethics, transparency, corruption prevention)

To complete these reports, companies need ESG data from their suppliers and service providers — including legal firms.

Expect questions such as:

• “Does your firm measure its carbon footprint?”
• “Do you have a diversity or equal pay policy?”
• “Are you compliant with anti-corruption and data protection regulations?”

You don’t need to produce a 100-page sustainability report. Instead, organise the key facts your clients will ask for.

2. How CSRD Affects Legal and Professional Service Firms

Most small and medium-sized legal firms are not directly in scope of the CSRD. However, your clients are, and they must assess ESG risks across their value chain — meaning you are indirectly covered.

Here’s how different firm types may be affected:

Tip: Even if you’re not legally required to report, being prepared strengthens client relationships and enhances your firm’s reputation for good governance.

3. The Framework to Use: VSME for Professional Services

The VSME Standard (EFRAG, 2024) was designed precisely for non-listed SMEs like law firms. It mirrors CSRD topics but in a proportionate, achievable format.

The Basic Module (B1–B11) includes:

• B1–B2: General information and sustainability policies
• B3–B7: Environmental data (energy, emissions, waste)
• B8–B10: Workforce and social metrics
• B11: Governance (anti-corruption, compliance)

By completing these sections once, you can reuse the information whenever clients send ESG questionnaires or supplier forms.

4. Common Client Questions — and How to Answer Them

🟢 Environmental (Energy & Emissions)

Typical questions:

• What are your firm’s annual energy and fuel use?
• Do you use renewable electricity?
• Do you measure your carbon footprint?

How to prepare:

• Keep annual electricity and heating bills.
• Record whether you use a green energy tariff.
• Use an online calculator (e.g. GHG Protocol or national tool) to estimate CO₂ emissions.
• Document any reduction initiatives (e.g. remote work, LED lighting).

Example response:

“Our offices use 100% renewable electricity. Total energy consumption in 2024 was 22,000 kWh, and we are implementing measures to further reduce consumption by 10%.”

🟣 Social (Workforce & Diversity)

Typical questions:

• How many employees does your firm have?
• Do you track gender balance or pay equity?
• What training or wellbeing measures do you provide?

How to prepare:

• List total employees, split by gender and contract type.
• Check compliance with national minimum wage and working time laws.
• Record annual training hours per employee.
• Describe diversity and inclusion policies.

Example response:

“We employ 18 people (60% female, 40% male). All are paid above the national minimum wage and receive an average of 20 training hours per year. The firm has a written equality policy covering recruitment and promotion.”

🟡 Governance (Ethics & Compliance)

Typical questions:

• Do you have policies on anti-bribery, corruption, and data protection?
• Have you had any compliance violations or fines?
• Who oversees ESG and compliance internally?

How to prepare:

• Gather all existing compliance documents: AML policy, GDPR policy, and code of conduct.
• Confirm there have been no corruption or bribery fines.
• Assign a partner or operations manager as the “sustainability contact”.

Example response:

“We maintain AML and GDPR compliance frameworks and a formal anti-bribery policy. No compliance breaches or fines were recorded in the past 12 months.”

5. Preparing Your Client-Facing Sustainability Summary

You can present your ESG information in a concise two-page format covering:

Format options:

• A short Sustainability Statement (PDF)
• A page on your website
• A section in your client tender documents

6. Optional: Using the VSME Comprehensive Module

If your clients include major listed companies or financial institutions, you may be asked for extra details such as:

• Scope 3 emissions (business travel)
• GHG reduction targets
• Human rights policy or grievance procedures
• Governance body diversity

These are covered in the VSME Comprehensive Module (C1–C9) and correspond to the ESRS disclosures under the CSRD. You can add them gradually as client expectations increase.

7. Steps to Get Ready

Tip: You don’t need a consultant — start simple, using real data and policies already in place.

8. Benefits for Legal SMEs

• Stronger client relationships – You can respond quickly and confidently to CSRD-related questions.
• Competitive advantage – Larger clients prefer suppliers with ESG transparency.
• Operational improvements – Energy, diversity, and governance tracking lead to better efficiency.
• Future readiness – When sustainability reporting becomes standard, your firm will already be prepared.

9. Example: ESG Snapshot for a Small Law Firm (VSME-Aligned)

This level of information satisfies most client ESG questionnaires and aligns with VSME Basic Module reporting.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
• Basic Module – Core SME sustainability disclosures (B1–B11)
• Comprehensive Module – Optional, more detailed disclosures (C1–C9)
• ESRS – European Sustainability Reporting Standards under CSRD
• Scope 1–3 emissions – Direct and indirect greenhouse gas emissions
• NACE code – EU classification of economic activities (e.g. M69.10 for legal services)
• Turnover – Annual revenue used for threshold calculation