Corporate Sustainability Reporting Directive (CSRD)

The foundation for this is provided by the European Sustainability Reporting Standards (ESRS), which establish a binding framework for uniform, comparable, and verifiable sustainability reporting.

Since January 1, 2024, large, capital market-oriented companies have generally been required to report in accordance with the Corporate Sustainability Reporting Directive (CSRD). However, the EU directive has not yet been fully transposed into German law.

For other companies, the first-time application is still ahead – but the regulatory environment continues to evolve.

As part of the so-called EU Omnibus procedure, the reporting obligations for companies in the so-called second and third waves have already been postponed by two years. In addition, the European Commission has proposed further extensive changes – including raising the employee threshold to 1,000 employees and significantly reducing the number of data points to be reported. The assurance of sustainability information will also remain limited to limited assurance in the future.

CSRD & Omnibus procedure: What matters now

Postponement of reporting obligations

For companies in the second wave (originally required to report under the CSRD in 2025) and the third wave (originally required to report in 2026), the reporting obligation has been postponed to 2027 (second wave) and 2028 (third wave). The first reports will therefore be published in 2028 and 2029, respectively.

Substantive changes to the CSRD

The EU’s amendments under the Omnibus procedure are primarily aimed at reducing the scope of companies required to prepare sustainability reports. The current draft directives include the following key points:

• Increase of the employee threshold to 1,000: Many companies would no longer be subject to the reporting requirement.
• Reduction of data points in the ESRS to simplify reporting.
• Limited assurance as the future standard for sustainability reporting.

It remains to be seen to what extent these changes—particularly the employee threshold of 1,000—will ultimately be implemented in the legislative process. What is certain, however, is that as a result of these changes, many large companies will no longer be required to prepare a sustainability report. Nevertheless, sustainability remains a key strategic topic—not only from a regulatory perspective but also as a driver of long-term corporate success.

Sustainability remains a strategic issue

These developments have created uncertainty, yet sustainability continues to be a strategic priority that goes far beyond mere regulatory compliance. Even without a legal obligation, many stakeholders—from investors and customers to employees—expect credible statements on environmental and social issues. Companies that report voluntarily gain a clear advantage: they strengthen their market position, enhance their resilience to future risks, and increase their attractiveness as employers.

Mandatory or voluntary: Sustainability reporting pays off

Whether mandatory or voluntary, a well-prepared sustainability report offers clear benefits. An increasing number of companies choose to report voluntarily in order to:

• Strengthen their reputation and build trust,
• Systematically identify sustainability risks,
• Leverage green finance opportunities,
• Enhance their employer attractiveness, and
• Meet stakeholder expectations.

Our services: Sustainability Reporting with a holistic approach

Our interdisciplinary team of CSR specialists, auditors, lawyers, tax advisors and IT experts provides tailored solutions for your sustainability reporting – from the initial analysis of your reporting obligations to the development of efficient reporting processes and audit-proof implementation. Together with you, we design reporting that meets regulatory requirements while creating real added value, perfectly aligned with your business model and industry.