CSRD Implementation Act 2025: Overview of Statements

With the Corporate Sustainability Reporting Directive (CSRD), the EU is setting new, significantly more demanding requirements for corporate sustainability reporting. The goal: companies should report more transparently on environmental, social, and governance (ESG) issues, standardized, digitized, and auditable. This affects large enterprises above the new thresholds and, in stages, many subsidiaries of international groups.

1. The CSRD Implementation Act 2025 at a Glance

In Germany, a revised draft bill for the CSRD Implementation Act has been available since July 2025. It regulates, among other things:

At the same time, the EU-wide Omnibus package has already fundamentally changed the landscape in parallel. The reporting obligation now applies only to companies with more than 1,000 employees AND more than €450m net turnover (both criteria cumulatively, in force since 18 March 2026). This has significantly reduced the number of companies in scope.

Companies and associations continue to sound the alarm. In their statements on the CSRD Implementation Act 2025, they criticize a lack of practical applicability, additional technical effort, and open legal questions. They demand improvements before the law is passed.

In this article, we take a closer look:

• What demands and proposals do leading players such as IDW, WPK, DRSC, the German Equity Institute, the German Banking Industry Committee, and the VDZ put forward?
• Where is there consensus and where do opinions diverge?
• What does all this mean for companies that will have to report in the future?

2. Who is behind the Statements? The most Important Players at a Glance

In the course of the debate surrounding the German CSRD implementation, numerous stakeholders have spoken out. Six organizations, in particular, play a central role. They represent, among others, auditors, the capital market, the real economy, industries with high reporting obligations, and accounting standard setters. Each brings its specific perspective.

1. IDW – Institute of Public Auditors in Germany The IDW represents the professional interests of auditors. It pays particular attention to the requirements for auditing the sustainability report, handling digital reporting formats, and defining audit obligations.

2. WPK – Chamber of Public Accountants As a public corporation, the WPK intensively deals with the legal framework of auditing. It demands clear delineations of auditor roles and warns against excessive requirements for auditors and audited companies.

3. DRSC – German Accounting Standards Committee The DRSC develops German accounting standards and represents Germany at the European level in the development of the ESRS (European Sustainability Reporting Standards). It particularly demands technical feasibility and coherence in the interplay between sustainability and financial reporting.

4. German Equity Institute (DAI) The DAI speaks for capital market-oriented companies and strongly focuses on bureaucracy costs, international competitiveness, and deadlines for implementation and auditing. It demands more practical relevance and flexibility for capital market-oriented companies.

5. German Banking Industry Committee (DK) As the umbrella organization for banks and savings banks, the DK is primarily concerned with feasibility in the financial sector. It emphasizes the risks of incoherent timelines and advocates for clear exemption rules and a reliable legal framework.

6. VDZ – Association of German Cement Manufacturers The VDZ represents the interests of the cement industry, an energy-intensive basic materials sector with high reporting obligations along the supply and production chain. It demands a practical and proportionate implementation, particularly to avoid duplicate reporting obligations and unnecessary regulatory burdens.

These six statements show: the CSRD Implementation Act 2025 encounters a broad field, from auditing professions to affected industries. In their diversity, they reflect which political and practical decisions must now be made.

3. What Do the Associations Demand? Key Criticisms at a Glance

The six statements on the CSRD Implementation Act 2025 differ in detail, but many demands are similar in their thrust: less complexity, more clarity, more practical applicability. Here are the key points summarized briefly for each association:

IDW – Institute of Public Auditors in Germany

• Retention of auditing by public accountants with clearly regulated additional qualifications.
• Demand for a realistic timeline for introduction and audit obligations.
• Rejection of the ESEF preparation obligation for the management report; disclosure solution preferred.
• Auditing should be risk-oriented and based on existing processes.

WPK – Chamber of Public Accountants

• Secure strict audit sovereignty with public accountants; no softening in favor of other providers.
• Clear limitation of the scope of audit to formal and substantively plausible auditing (Limited Assurance).
• Warning against additional bureaucracy due to technical formats like ESEF.

DRSC – German Accounting Standards Committee

• Rejection of the preparation obligation in ESEF format: causes additional effort, legal uncertainty, and media discontinuities.
• Demand for a disclosure solution analogous to previous financial reporting.
• Emphasize consistency of sustainability and financial reporting ("connectivity").
• Criticism of technical ambiguity (e.g., regarding XBRL taxonomy, archiving, signature).

German Equity Institute (DAI)

• Rejection of mandatory ESEF preparation, especially for non-capital market-oriented companies.
• Introduction of a "one-stop report" to avoid parallel reporting obligations (e.g., Supply Chain Due Diligence Act).
• More flexible transition periods and more implementation leeway for companies demanded.
• Audit obligation by public accountants with industry-specific additional qualifications supported.

German Banking Industry Committee (DK)

• Warns against a hasty entry into force and demands adaptation to ongoing EU procedures.
• Open questions regarding group exemption and intertwining of deadlines within corporate groups.
• Supports the disclosure solution for the ESEF format.
• Suggests more practical definitions for audit content and consolidation scope.

VDZ – Association of German Cement Manufacturers E.V.

• Start national implementation only after completion of EU adjustments (Omnibus package).
• Reduction of duplicate reporting obligations (CSRD vs. Supply Chain Due Diligence Act) urgently needed.
• Criticism of ESEF obligation as impractical, especially for medium-sized companies.
• Admission of further auditors besides public accountants proposed to relieve the market.

4. What Unites and Divides the Associations

The six statements on the CSRD Implementation Act 2025 differ in tone, but not always in content. While the perspectives vary, clear patterns emerge in central aspects. In other areas, however, the views are quite controversial.

4.1 Common Demands: More Pragmatism, Less Complexity

Rejection of the ESEF Preparation Obligation All six organizations oppose the mandatory preparation of the management report in ESEF/XHTML format. Instead, the so-called disclosure solution is preferred, i.e., digital formatting solely for the purpose of publication, not as a legally authoritative document.

Priority for Practical Applicability and Legal Certainty There is agreement that the draft law is rushed. Many demand that it should only come into force after the completion of the EU-wide Omnibus adjustments. Companies need clarity on what applies when for whom.

Avoidance of Duplicate Reporting Obligations In particular, the German Equity Institute, the VDZ, and the DK urge to harmonize sustainability reporting with other legal reporting obligations (e.g., Supply Chain Due Diligence Act). The idea: a "one-stop report."

Limited Audit Scope with Clear Responsibility There is agreement that the audit of the sustainability report must not escalate into a full audit. The demanded "Limited Assurance" should remain consistent. The IDW, WPK, and DAI emphasize the priority of public accountants, while also requiring practical qualifications.

Align Consolidation Scope with Financial Reporting Several organizations, especially DRSC, DK, and VDZ, demand that the sustainability report be allowed to use the same consolidation scope as financial reporting. This is intended to reduce effort and improve comparability.

4.2 Controversies and Differences: Who May Audit and to What Extent?

Despite many agreements, clear differences emerge on some issues:

Who may audit? While IDW and WPK strictly insist on auditing by public accountants, the VDZ is more open: other qualified auditors should also be admitted to avoid capacity bottlenecks.

Technology vs. Feasibility The DRSC criticizes the draft in particularly detailed technical terms, focusing on iXBRL, signature requirements, media discontinuities, and format issues. Others, like the DAI or the VDZ, rather emphasize the bureaucratic effort for companies and demand simple solutions.

Timing of Implementation While DRSC and DK specifically point to the ongoing EU adjustments and their delays, WPK and IDW express themselves more cautiously and focus more on substantive design than on deadline postponement.

Industry Interests The differences often reflect industry-specific interests:

• The DAI focuses on listed large enterprises.
• The DK thinks in terms of group structures and reporting obligations along the group.
• The VDZ brings in the perspective of an energy-intensive industry that particularly suffers from regulatory burden.

4.3 Interim Conclusion

The associations do not want a "return to voluntary CSR," but they demand a realistic and implementable sustainability reporting that does not overwhelm companies with bureaucracy and that fulfills the actual purpose of the CSRD: credible, traceable sustainability data.

5. Comparison of Statements: Who Stands Where?

To make the complexity of the statements tangible, the following table summarizes the core positions on central aspects:

Despite different focuses, the associations share a common goal: the implementation of the CSRD should be legally compliant, but also economically viable and technically manageable. The ESEF preparation, audit obligations, and harmonization with other laws are particularly in focus, with sometimes very clear demands on the legislator.

6. Conclusion: A Law with Repercussions

The draft bill for the CSRD Implementation Act 2025 is more than a technical update of the HGB. It is a balancing act between EU requirements and national implementability. The associations' statements clearly show: in its current form, the law is largely not practical.

6.1 What the Legislator Should Take Away

• The unanimous rejection of the ESEF preparation obligation for the management report is a clear signal. The disclosure solution is tried and tested in practice and offers the same transparency without the massive additional technical effort.
• The audit by public accountants is generally supported, but it must be efficient, risk-oriented, and not artificially complicated. The discussion about opening up to other auditors is a question of capacity and trust.
• Companies need legal certainty and no changes during ongoing operations. The legislator should adapt the timeline to the EU process and not set implementation deadlines before Brussels has finalized its position.
• A "one-stop report" that consolidates various reporting obligations (e.g., CSRD, Supply Chain Due Diligence Act) would be a real step forward and would reduce bureaucracy instead of building it up.

6.2 What Companies Can Do Now

• Even if the law is not yet final: the direction is clear. The CSRD is coming and it will require structured, auditable ESG data in the future.
• Companies should proactively address the interlinking of sustainability and financial reporting, clarify responsibilities, and build competencies.
• Those operating internationally should analyze potential consolidation obligations and reporting obligations within the group, otherwise unexpected additional effort threatens here.

6.3 What This Means for Practice

Sustainability reporting will become an integral part of corporate communication, legally binding, auditable, and public. The political course for this is being set now. If the associations' recommendations are heard, the CSRD Implementation Act 2025 could be a functional framework for greater sustainability transparency.

7. Further Links and Tools

The CSRD and its national implementation will intensively occupy many companies, consultants, and auditors in the coming months. Those who want to be well-prepared should now have the right information sources and tools at hand.

Official Documents and Statements

• Draft bill of the Federal Ministry of Justice (BMJ) for the CSRD Implementation Act 2025.
• Overview of the CSRD on the EU Commission's website.

The six analyzed statements:

• Institute of Public Auditors in Germany (IDW)
• Chamber of Public Accountants (WPK)
• German Accounting Standards Committee (DRSC)
• German Equity Institute (DAI)
• German Banking Industry Committee (DK)
• Association of German Cement Manufacturers e.V.

Frequently asked questions about the CSRD Implementation Act