CSRD implementation in Germany: orientation in uncertain times
The lack of CSRD implementation in Germany is causing uncertainty among companies. This guide shows you what you can do now.
- Germany has not yet adopted its national CSRD transposition law (as of September 2026). Following the public hearing on 13 April 2026 there is no fixed date: according to the federal government (27 August 2026), the further timetable is up to the Bundestag.
- Until the new law is in place, the CSR Directive Implementation Act (CSR-RUG) continues to apply. Because of the late transposition, EU infringement proceedings have been pending against Germany since September 2024.
- The Omnibus Directive has been in force since 18 March 2026: from financial year 2027, only companies with more than 1,000 employees AND more than €450m net turnover are required to report. Both criteria must be met.
- The revised ESRS (Delegated Regulation (EU) 2026/1563, mandatory from financial year 2027) and the VS (Voluntary Standard, formerly VSME; Delegated Regulation (EU) 2026/1560) were published in the EU Official Journal on 21 September 2026. Companies outside the new scope can report voluntarily using the VS.
- No-regret moves (materiality analysis, data management, internal responsibilities) remain worthwhile regardless of how the law develops.
- Early action creates competitive advantages: better access to funding, stronger investor appeal, and a clearer picture of sustainability risks.
The Corporate Sustainability Reporting Directive (CSRD) requires large companies across Europe to publish an annual sustainability report alongside their financial report. While many EU countries (such as France and Italy) have transposed the directive into national law, and Austria's Sustainability Reporting Act (NaBeG) has been in force since 19 February 2026, Germany is still lagging behind.
This delay is causing uncertainty for companies. The German government's pushback towards the EU on requirements such as double materiality and the ESRS has further complicated the situation. Many companies are asking: what rules will really apply, and how do I prepare?
This article gives you guidance and shows how you can best prepare for the CSRD and its implementation in Germany. One thing is clear: for large companies above the new Omnibus thresholds, the reporting obligations will apply from financial year 2027 at the latest.
The Omnibus package entered into force on 18 March 2026. From financial year 2027, reporting is mandatory only for companies with more than 1,000 employees AND more than €450m net turnover (both criteria cumulatively). Germany's national CSRD transposition law (CSRD-UmsG) is not yet adopted. After the public hearing in the Bundestag's Legal Affairs Committee on 13 April 2026, no second/third reading has taken place.
There is no official date for adoption. In its reply of 27 August 2026 (Bundestag printed paper 21/7745), the federal government stated that it is pushing for swift transposition and is in contact with the coalition parliamentary groups, but that the further timetable of the parliamentary procedure is up to the Bundestag.
Until then, the CSR Directive Implementation Act (CSR-RUG) continues to apply in Germany. EU infringement proceedings over the late transposition (deadline: 6 July 2024) have been pending since September 2024. For reporting year 2025, the CSR-RUG still applies under current law and there is no obligation to apply the ESRS. However, the coalition amendment of 31 March 2026 would apply the new rules retroactively to financial years beginning on or after 1 January 2025; the DRSC and IDW consider this constitutionally questionable.
What is the CSRD and why is it important?
The CSRD is an EU-wide directive that transforms sustainability reporting for companies. It replaces the previous Non-Financial Reporting Directive (NFRD) and introduces more comprehensive and detailed requirements.
The central objectives of the CSRD
- Uniform reporting standards: With the Sustainability Reporting Standards (ESRS), the CSRD creates a clear framework for environmental, social and governance (ESG) issues.
- Double materiality: Companies must identify and disclose both the impact of their actions on the environment and society, and the financial impact of sustainability-related risks, as part of a double materiality analysis.
- Transparency for investors and stakeholders: The CSRD ensures that investors, customers, suppliers and other stakeholders receive relevant information to make sustainable decisions.
Timeline of CSRD implementation in Germany
The implementation of CSRD in Germany has been shaped by delays and uncertainties. Although the EU issued clear guidelines, Germany has not yet fully implemented them into national law. Here are the key events in chronological order.
Up to July 2024
1. Adoption of the CSRD at EU level (November 2022)
The EU officially adopted the CSRD to comprehensively standardise sustainability reporting for companies. The directive came into force on 5 January 2023, and member states were required to transpose it into national law by 6 July 2024.
2. German draft bill on CSRD implementation (March 2024)
A draft bill for the German CSRD Implementation Act was published in March 2024 but not officially enacted. It indicated Germany intended to adopt the EU requirements 1:1, without specific adjustments or simplifications. Business associations criticised this approach strongly.
3. Delay in implementation (July 2024)
Germany missed the legal transposition deadline of 6 July 2024. This increased uncertainty for companies expecting to comply with the new requirements from the 2025 reporting year.
4. Government draft on CSRD implementation (July 2024)
On 24 July 2024, the Federal Ministry of Justice published a government draft. It provided for near-complete transposition of CSRD requirements into German law, including the ESRS, with only minor national adjustments.
From July 2024 onwards
5. EU publishes updated German translation of the CSRD (August 2024)
In August 2024, a corrigendum to the German version of the CSRD was published in the EU Official Journal. It clarified linguistic inaccuracies in the original translation, particularly around double materiality and reporting obligations.
6. EU infringement proceedings against Germany (September 2024)
Because Germany missed the transposition deadline, the European Commission opened infringement proceedings against Germany in September 2024. They are still pending.
7. EU announces Omnibus initiative (November 2024)
In November 2024, the European Commission announced an Omnibus proposal to consolidate the CSRD, the CSDDD and the EU taxonomy, with the goal of simplifying reporting and reducing bureaucratic burden.
8. German government pushback towards the EU (December 2024)
The German government lobbied the Commission to simplify CSRD requirements, calling for:
- A reduction in ESRS data points
- Measures to counter the "trickle-down" effect along the supply chain to relieve SMEs
- A postponement of reporting obligations by two years
9. Cabinet adopts new government draft (September 2025)
On 3 September 2025 the federal cabinet adopted the government draft of the CSRD Implementation Act (Bundestag printed paper 21/1857 of 29 September 2025). The first reading in the Bundestag took place on 9 October 2025, and the Bundesrat delivered its opinion on 17 October 2025.
10. Omnibus package enters into force (March 2026)
The Omnibus Directive entered into force on 18 March 2026. From financial year 2027, the reporting threshold requires more than 1,000 employees AND more than €450m net turnover (both criteria cumulatively). Member states must transpose the amended rules by 19 March 2027.
11. Coalition amendment (31 March 2026)
The coalition parliamentary groups CDU/CSU and SPD tabled an amendment to the bill that takes the Omnibus I Directive (EU) 2026/470 into account. Under the amendment, the new rules would already apply to financial years beginning on or after 1 January 2025, i.e. retroactively. The DRSC and IDW have criticised this.
12. Public hearing in the Legal Affairs Committee (13 April 2026)
The Bundestag's Legal Affairs Committee held a public hearing on the CSRD Implementation Act. No second/third reading in the Bundestag has taken place since.
13. Draft revised ESRS published for consultation (May 2026)
On 6 May 2026 the Commission published a draft of simplified ("revised") ESRS for public consultation (feedback period until 3 June 2026).
14. Revised ESRS and VS adopted (3 July 2026)
The Commission adopted the revised ESRS and the voluntary standard VS (formerly VSME) as delegated acts. Key changes: mandatory data points cut by over 60%, total data points by over 70%, and a simplified materiality assessment.
15. Federal government names no date (27 August 2026)
Asked when the procedure would be concluded, the federal government replied (Bundestag printed paper 21/7745) that it is pushing for swift transposition, but that the further timetable of the parliamentary procedure is up to the Bundestag. There is therefore no official date for adoption.
16. Publication in the EU Official Journal (21 September 2026)
The revised ESRS were published as Delegated Regulation (EU) 2026/1563 and apply mandatorily to financial years beginning on or after 1 January 2027. The VS was published as Delegated Regulation (EU) 2026/1560 and has been in force since 24 September 2026.
What should German companies do now?
The non-implementation of EU directives typically creates legal uncertainty and additional expense for companies. Early action and alignment with EU requirements are therefore advisable.
Despite the delayed national implementation, German companies should actively prepare for the new requirements. The ESRS provide a clear basis for reporting. The revised ESRS were adopted on 3 July 2026 and published in the EU Official Journal on 21 September 2026 as Delegated Regulation (EU) 2026/1563. They apply mandatorily to financial years beginning on or after 1 January 2027; for financial year 2026, companies can choose between the original ESRS, the original ESRS with reliefs, or the revised ESRS.
How you can prepare despite the delay
Companies should focus on "no-regret moves": risk-free, forward-looking measures that help overcome uncertainty and create future compliance, efficiency and competitiveness regardless of the final implementation timeline. Here is what we recommend:
1. Clarify responsibilities
Define which individuals and teams will take on key roles in sustainability reporting if you have not done so already.
2. Carry out a double materiality analysis
The double materiality analysis offers companies long-term benefits, regardless of regulatory changes. It creates the foundation for well-founded sustainability decisions and strategic action, whatever the final regulatory shape. The materiality analysis is at the heart of the CSRD, so it is hard to imagine it becoming irrelevant.
We recommend the materiality analysis Excel template, adapted to the revised ESRS, or the Materiality Master software to carry out the analysis as cost-effectively and time-efficiently as possible.
3. Write a simplified test report using the VSME
EFRAG published a simplified voluntary sustainability reporting guideline known as the VSME standard in December 2024. On 3 July 2026 it was adopted as the "VS (Voluntary Standard)", which builds on the VSME and has been in force since 24 September 2026 as Delegated Regulation (EU) 2026/1560. It is open to all companies that are not subject to CSRD reporting. From financial year 2027, companies subject to the CSRD may not request information beyond the VS from value-chain partners with up to 1,000 employees. The standard requires companies to publish only a manageable number of data points.
A ready-to-fill Word template for a CSRD-compatible VS sustainability report, including a step-by-step guide with practical tips.
It is also advisable to follow CSRD news closely, listen to sustainability podcasts, follow webinars and attend CSRD training courses to stay current.
Subscribe to the free CSRD Kompass newsletter and receive the most relevant developments every two weeks by email.
Opportunities even without a completed German transposition
Preparing for the CSRD now offers real opportunities. Those who use the requirements strategically can gain a competitive advantage and benefit long-term.
- Transparency and credibility: Structured sustainability reporting builds trust with stakeholders. Companies that disclose their sustainability performance stand out and strengthen their reputation.
- Investor appeal: ESG-compliant companies are increasingly preferred, as sustainable investments are seen as future-proof.
- Customer loyalty: Consumers place more and more value on sustainable products and services. Transparent reporting can be a decisive factor.
- Efficiency through data analysis: Collecting sustainability data helps identify optimisation potential in processes, supply chains and resource use.
- Early regulatory adaptation: Companies that implement CSRD requirements now are ahead of future legal adjustments. A proactive approach minimises risks and avoids costly rework.
- Innovation: Working with sustainability issues promotes new products, business models and technologies, opening up new markets such as the circular economy or renewable energies.
- Access to funding: Many national and EU funding programmes target companies actively committed to sustainability. A credible sustainability strategy also opens doors to new partnerships and markets.
Conclusion
The delay in national implementation creates hurdles for German companies, but early action is crucial. Aligning with the ESRS now prepares you better for the requirements and secures strategic advantages.
The keys to successful implementation are:
- Early planning: Robust data management systems and a materiality analysis create a solid foundation.
- Flexibility: A well-developed sustainability strategy lets you react quickly to regulatory changes.
- Long-term perspective: Sustainability is an opportunity to increase innovative strength, efficiency and competitiveness. It is not just a legal obligation.
The CSRD is more than a guideline. It is a tool for actively shaping sustainable business practices. Companies that accept the challenges now can take a pioneering role and strengthen their future viability.
Frequently asked questions about CSRD implementation in Germany
Is Germany still obligated to transpose the CSRD into national law?
Yes. Germany's national CSRD transposition law is not yet adopted as of September 2026. There has been no second/third reading since the public hearing on 13 April 2026, and there is no fixed date: according to the federal government (27 August 2026), the further timetable is up to the Bundestag. Until then, the CSR-RUG continues to apply. Member states must transpose the Omnibus amendments to the CSRD by 19 March 2027. For reporting year 2025, the CSR-RUG still applies under current law and there is no obligation to apply the ESRS. However, the coalition amendment of 31 March 2026 would apply the new rules retroactively to financial years beginning on or after 1 January 2025; the DRSC and IDW consider this constitutionally questionable.
Who still has to report under the new Omnibus thresholds?
The Omnibus Directive has been in force since 18 March 2026: from financial year 2027, the reporting obligation applies only to companies with more than 1,000 employees AND more than €450m net turnover. Both criteria must be met cumulatively. Many companies that previously expected to be in scope are now exempt.
What can companies outside the new CSRD scope do?
The VSME standard has become the "VS (Voluntary Standard)", in force since 24 September 2026 as Delegated Regulation (EU) 2026/1560. It is a practical option for companies outside the mandatory scope: it covers only a manageable number of data points and is open to all companies not subject to CSRD reporting. Reporting voluntarily also prepares you for any future scope changes and meets growing demand from customers and investors.
Why is the double materiality analysis still worth doing?
The double materiality analysis is the foundation of the CSRD and offers strategic value regardless of regulatory changes. It reveals risks and opportunities early, supports better decision-making, and is central to any future reporting. Tools like the materiality analysis Excel template or Materiality Master make the process significantly more efficient.
