Implementing CSRD Reporting Digitally and in Compliance

The Corporate Sustainability Reporting Directive (CSRD) expands the sustainability reporting obligations and affects a variety of companies within the EU. The CSRD reporting applies to the following companies:

1. Large companies that meet the EU criteria for "large companies". These criteria are:

- An average of at least 250 employees,
- A balance sheet total of at least €25 million,
- Net revenues of at least €50 million.

2. Listed companies, regardless of their size. This also includes small and medium-sized enterprises (SMEs).

3. Subsidiaries of large companies. If the parent company does not report, subsidiaries that are part of a large corporate group must also report.

4. Non-European companies with significant operations in the EU. Non-EU companies that generate net revenues of more than €150 million in the EU and have at least one subsidiary or branch in the EU are also subject to the reporting obligation.

The implementation of these new regulations will take place in stages from the financial year 2024 and will be extended to more companies in the following years. The goal of the CSRD is to improve the transparency and comparability of sustainability information and to promote a more sustainable economy.

The Corporate Sustainability Reporting Directive (CSRD) will be implemented in stages to give companies enough time to adjust. The implementation will take place in several phases:

2024:
From 1 January 2024, large companies already subject to the Non-Financial Reporting Directive (NFRD) must meet the new CSRD requirements. This mainly affects large publicly listed companies with more than 500 employees.

2025:
From 1 January 2025, additional large companies that are not subject to the NFRD but meet the CSRD criteria (more than 250 employees, more than €50 million in revenue, more than €25 million in balance sheet total) must comply with the new reporting requirements.

2028:
From 1 January 2028, small and medium-sized companies (SMEs) that are publicly listed, as well as small and non-complex credit institutions and captive insurance companies, must comply with the CSRD requirements and report accordingly.

2028:
From 1 January 2028, non-European companies that generate net revenues of more than €150 million in the EU and have at least one subsidiary or branch in the EU will also be required to comply with the CSRD requirements.

This staggered introduction allows companies to gradually prepare for the new reporting obligations and ensures they can implement the necessary systems and processes.

The CSRD (Corporate Sustainability Reporting Directive) requires companies to report comprehensively on their sustainability performance. They must describe and document various key areas in detail. The main contents are:

Environmental Aspects:
This refers to the impact of the company on the environment and climate, climate protection measures, strategies for adapting to climate change, energy consumption and efficiency, water resource use, waste management, and the protection of biodiversity and ecosystems.

Social and Employee Aspects:
This covers measures to promote gender equality, working conditions (including health and safety at work), workers' rights and social dialogue, compliance with labour standards and human rights throughout the supply chain, as well as diversity and inclusion in the workplace.

Governance and Management:
This includes the company’s governance and supervisory structure, corporate ethics and integrity, anti-corruption and anti-bribery measures, internal control and risk management systems, as well as the independence and qualifications of the management board and supervisory board members.

Economic Sustainability:
This covers the business model and corporate strategy in terms of sustainability, opportunities and risks related to sustainability, sustainability goals and progress towards achieving these goals, and the impact of sustainability factors on financial performance and corporate strategy.

Data and Performance Indicators:
This relates to quantitative and qualitative performance indicators that make sustainability performance measurable, comparable and consistent data to assess progress over time, as well as target settings and benchmarks.

Supply Chain and Business Partners:
This includes sustainability practices throughout the supply chain, assessing and monitoring suppliers regarding social and environmental standards, as well as collaborating with suppliers and business partners to improve sustainability performance.

Reporting Standards and Transparency:
This concerns the application of recognised reporting standards such as the European Sustainability Reporting Standards (ESRS), ensuring transparency and accessibility of reports for all relevant stakeholders, as well as external auditing and verification of sustainability reports.

These comprehensive reporting obligations are intended to ensure that companies transparently and understandably present their sustainability efforts, meeting the increasing demands of investors, customers, and society.

The implementation of the CSRD (Corporate Sustainability Reporting Directive) in Germany is carried out by adapting national laws and regulations to the requirements of the EU Directive. The key steps and measures for implementation are:

Adjustment of the Commercial Code (HGB):
The HGB will be amended to integrate the new reporting obligations of the CSRD. This particularly affects Sections 289b to 289e and 315b to 315d HGB, which previously regulated non-financial reporting.

Mandatory Reporting:
Companies that fall under the CSRD must create detailed reports on environmental, social, and governance (ESG) topics. This applies to large companies, publicly listed companies, as well as certain non-European companies with significant operations in the EU.

European Sustainability Reporting Standards (ESRS):
Reporting must be done in accordance with the European Sustainability Reporting Standards (ESRS). These standards provide detailed guidelines for the contents and formats of the reports.

External Auditing and Verification:
Sustainability reports must be reviewed for accuracy and completeness by external auditors. This external audit is intended to ensure that the reports meet the high-quality standards. In Germany, the audit is conducted as a so-called "limited assurance" audit, meaning the auditor provides an opinion on the plausibility and reliability of the information.

The CSRD is intended to make sustainability reporting more consistent and transparent across the EU, facilitating comparability and enhancing the credibility of corporate sustainability performance.