CSRD in Germany: National Law, Status, Scope and First Reporting Years

The EU deadline of 6 July 2024 (Article 5(1) of Directive (EU) 2022/2464) has passed without a German act. The Corporate Sustainability Reporting Directive (CSRD) binds Germany to transpose it; until the bill is adopted, its reporting rules reach German companies only through the Handelsgesetzbuch (HGB, the German Commercial Code). What the Directive itself requires is set out in the CSRD explained after the Omnibus.

The five key figures for Germany are listed below.

• EU transposition deadline: 6 July 2024, on the CSRD timeline
• Bill: BT-Drs. 21/1857, pending in committee as of 29 October 2026
• Law in force: the CSR-RUG, BGBl. I 2017 S. 802
• Draft scope from financial year 2027: more than 1,000 employees and more than EUR 450 million net turnover
• Assurance today: a presence check only (§ 317(2) sentence 4 HGB)

Has Germany Transposed the CSRD? Status as of 29 October 2026

No: as of 29 October 2026 Germany has transposed neither the CSRD nor the Stop-the-clock Directive (EU) 2025/794, whose deadlines passed on 6 July 2024 and 31 December 2025, nor Directive (EU) 2026/470 (Omnibus I), which is due by 19 March 2027. EUR-Lex records no German national measure for Directive (EU) 2022/2464 or Directive (EU) 2025/794 as of 29 October 2026; a record shows a notification, not a finding that transposition is complete. The deadline in Article 5(1) of Directive (EU) 2026/470 has not passed, so the missing transposition of that act is not yet late.

The table below lists the dated steps, from EUR-Lex, the Commission, the Bundestag, the Federal Ministry of Justice and the DRSC.

The Government Bill BT-Drs. 21/1857 and the Lapsed First Bill

The federal cabinet adopted the government bill on 3 September 2025, and the Bundestag printed it as Drucksache 21/1857 on 29 September 2025. Its German title, "Gesetz zur Umsetzung der Richtlinie (EU) 2022/2464 hinsichtlich der Nachhaltigkeitsberichterstattung von Unternehmen in der durch die Richtlinie (EU) 2025/794 geänderten Fassung" (act transposing the CSRD as amended by the Stop-the-clock Directive), has the short form CSRD-Umsetzungsgesetz (CSRD-UmsG). The Federal Ministry of Justice and Consumer Protection (BMJV) leads; its ministry draft dates from 10 July 2025, and the bill transposes "nach dem Prinzip 1:1" (one to one) with selective adjustments.

The first reading took place on 9 October 2025 (Plenarprotokoll 21/31), and the Committee on Legal Affairs and Consumer Protection (Rechtsausschuss) leads the work on the bill. The Bundesrat gave its statement at its 1058th session on 17 October 2025, and the government replied on 29 October 2025 (Gegenäußerung, BT-Drs. 21/2465). According to the draft, the bill does not require Bundesrat consent. An earlier bill, BT-Drs. 20/12787, lapsed at the end of the 20th legislative period (Diskontinuität, discontinuity).

The Coalition Amendment of 30 March 2026 and the Two Amending Directives

The governing coalition tabled an amendment to the bill in the Legal Affairs Committee on 30 March 2026 (Ausschussdrucksache 21(6)73), which also covers Directives (EU) 2025/794 and 2026/470. The amendment brings the Omnibus values into the German draft: the new scope from financial year 2027, the value-chain cap and higher thresholds for non-EU groups. The committee held a public hearing on 13 April 2026.

The last recorded step is a letter of 20 October 2026 from the DRSC (Deutsches Rechnungslegungs Standards Committee, the private national accounting standard setter) to the Legal Affairs Committee as lead committee. The Omnibus I amendments to the CSRD that 21(6)73 builds in therefore remain draft German law, and no adoption date can be given as of 29 October 2026.

EU Infringement Procedure against Germany

The European Commission opened an infringement procedure against Germany in September 2024 for not transposing the CSRD (Article 258 TFEU), a step the government bill itself cites. The Commission decided the letters of formal notice to 17 Member States, Germany among them, on 25 September 2024 and announced them on 26 September 2024, with two months to respond. The German case, INFR(2024)0216, is open as of 29 October 2026, with the letter of formal notice as its last step, and adopting the bill is the step that closes the gap it addresses.

What German Companies Must Report Today under the HGB

Until the bill is adopted, German companies report under the CSR-RUG of 11 April 2017 (BGBl. I 2017 S. 802), which transposed Directive 2014/95/EU into the HGB and has applied to financial years beginning after 31 December 2016 (Art. 80 EGHGB). The duty falls on large, capital-market-oriented companies with on average more than 500 employees (§ 289b(1) HGB) and on capital-market-oriented parents whose groups have more than 500 employees in total (§ 315b HGB).

The EU wave-1 years (financial years 2024 to 2026) did not become German law: for financial year 2024, German wave-1 companies were bound by the HGB duty, not by an ESRS duty.

The statutory auditor only checks whether the statement was presented (§ 317(2) sentence 4 HGB). The non-financial statement under §§ 289b to 289e HGB has its own page, section by section.

Who Would Report under the German Bill? Draft Scope and First Reporting Years

The German bill, in the wording of the coalition amendment, would apply the CSRD rules first to large public-interest entities with more than 500 employees for financial years beginning after 31 December 2024 and, from financial year 2027, to companies with more than 1,000 employees and more than EUR 450 million net turnover. Every value in this section is draft as of 29 October 2026. The new test would apply regardless of capital-market orientation, matching the removal of listed SMEs from the CSRD by Directive (EU) 2026/470.

The table below compares the five draft groups.

Wave 1 and the Relief up to Financial Year 2026 in the Draft

Article 96(1) EGHGB-E would apply the new rules to large public-interest entities with more than 500 employees for financial years beginning after 31 December 2024, so their last CSR-RUG year would be the financial year beginning before 1 January 2025. Small and non-complex institutions and captive insurers are excluded from this first group.

Article 96(8) EGHGB-E grants relief in two draft wordings. The government bill would exempt companies with on average not more than 1,000 employees for financial years beginning before 1 January 2027; amendment 21(6)73 requires not more than 1,000 employees "and" not more than EUR 450 million turnover at the balance-sheet date. The EU option behind the relief, the last subparagraph of Article 5(2) of Directive (EU) 2022/2464 added by Article 3(1)(c) of Directive (EU) 2026/470, lets Member States exempt wave-1 undertakings not exceeding EUR 450 million net turnover "or" an average of 1,000 employees for financial years starting between 1 January 2025 and 31 December 2026.

Large Companies from Financial Year 2027 and Non-EU Groups from 2028 in the Draft

The amendment would rewrite §§ 289b(1) and 315b(1) HGB so that, from financial year 2027, a company or group reports if it has more than EUR 450 million net turnover and on average more than 1,000 employees, whether or not it is listed.

Two further draft rules follow Directive (EU) 2026/470. § 289c HGB-E would introduce the value-chain cap from 1 January 2027: from a protected undertaking, with on average not more than 1,000 employees in the preceding financial year, a reporting company could not require information beyond the standards for voluntary use adopted under Article 29ca of Directive 2013/34/EU, the voluntary standard (VS, formerly VSME). §§ 315h to 315j HGB-E would set the non-EU thresholds at EUR 200 million turnover of the EU subsidiary or branch in the preceding financial year and EUR 450 million EU and EEA turnover of the ultimate parent in the two last consecutive financial years, for financial years beginning on or after 1 January 2028. These values would replace the EUR 40 million and EUR 150 million of the government bill.

The draft mirrors Article 19a(1) and Article 29a(1) of Directive 2013/34/EU as amended by Directive (EU) 2026/470, which apply the test individually or on a consolidated basis. The CSRD thresholds for large companies show how both criteria are counted at EU level.

Government Estimates of Companies and Cost

The government bill of 29 September 2025 estimated about 290 companies in the first group, reporting in 2026 on financial year 2025, and about 15,250 under the original CSRD scope from financial year 2028. For the Commission's Omnibus proposal, the bill's scenario counts up to 3,900 companies, with annual cost of about EUR 430 million instead of EUR 1.65 billion and one-off cost of about EUR 230 million instead of EUR 880 million. These figures are estimates in BT-Drs. 21/1857, not a count of companies in scope after the Omnibus; no official count of that kind exists.

What follows once you are in scope: the CSRD compliance plan step by step.

Assurance of Sustainability Reports in Germany: Current Law and Draft

Under the law in force as of 29 October 2026, the statutory auditor only checks whether the non-financial statement was presented (§ 317(2) sentence 4 HGB); the bill would require a separate assurance engagement by a Wirtschaftsprüfer or vereidigter Buchprüfer registered for sustainability assurance (§ 324e HGB-E). Under the draft, Wirtschaftsprüfer (public auditors), vereidigte Buchprüfer (sworn auditors) and their firms would need a register entry under § 38 No. 1 (g) or No. 2 (k) of the Wirtschaftsprüferordnung (WPO), and the statutory auditor could also be the sustainability auditor.

The bill does not allow independent assurance services providers (IASPs), an option Article 34(4) of Directive 2013/34/EU leaves to Member States. At EU level, the limited assurance of CSRD reporting required by Article 34(1)(aa), as replaced by Directive (EU) 2026/470, is the only assurance level; the EU limited-assurance standard is not adopted as of 29 October 2026 (due by 1 July 2027). The draft does not use the option of Article 28a(5) of the Audit Directive, so the auditor would issue a separate assurance report (Prüfungsvermerk).

Auditor oversight stays with APAS (Abschlussprüferaufsichtsstelle at the BAFA), which would receive 9.5 additional posts under the bill. Under the government bill, the sustainability report would become part of the management report (Lagebericht) and would be disclosed with it, together with the assurance report, through the Unternehmensregister (company register) under § 325 HGB.

The table below compares the law in force with the draft.

Fines and Coercive Penalties in Germany under §§ 334 and 335 HGB

A breach of the non-financial reporting rules of the HGB is an administrative offence with a fine of up to EUR 50,000 (§ 334(3) HGB), rising for capital-market-oriented companies to the higher of EUR 2 million or twice the economic benefit for natural persons and, for legal persons, to the highest of EUR 10 million, 5 % of annual total turnover or twice the benefit (§ 334(3a) HGB). Failure to disclose leads to an Ordnungsgeld (coercive fine) of EUR 2,500 to EUR 25,000, imposed by the Bundesamt für Justiz (Federal Office of Justice) under § 335(1) HGB.

The bill would extend §§ 331 and 334 HGB to the sustainability report and add a new § 332(1a) HGB. How enforcers and fines compare at EU level is set out under CSRD penalties and enforcement. ESMA's GLESI compliance table of 24 August 2026 lists the Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) as the German enforcer, and the bill would place the sustainability reports of companies subject to the Bilanzkontrolle (financial reporting enforcement) under BaFin's enforcement, with matching information powers towards their auditors (§ 107(5) WpHG-E).

The table below sets out the sanctions of the HGB in force, each with its condition.

Open Points in the German Draft Raised by the DRSC

In its letter to the Legal Affairs Committee of 20 October 2026, the DRSC asked for three clarifications of the draft scope: the turnover test should cover the 12 months before the balance-sheet date, the group test should use consolidated revenue, and the bill should say which two financial years count for first application in 2027. The draft words the turnover test "am Abschlussstichtag" (at the balance-sheet date), while § 267 HGB counts the 12 months before that date. Consolidated revenue would match Article 29a(1) of Directive 2013/34/EU, which tests the group "on a consolidated basis".

The DRSC also took a critical position in April 2026 on the retroactive effect of the bill, which would reach back to financial year 2025 for wave 1. The bill remains in committee as of 29 October 2026, so each test can still change.

Germany in the EU-Wide Comparison

Germany has no CSRD transposing act as of 29 October 2026, and its draft is one row of the EU-wide comparison. The EU-wide CSRD transposition tracker follows the CSRD, Stop-the-clock and Omnibus I status of the 27 Member States and Norway.

Detail Pages on German Sustainability Reporting

The four detail pages below cover German reporting and two neighbouring countries.

• CSR-RUG and the non-financial statement: the duty in force, section by section.
• German Sustainability Code (DNK) and the voluntary standard: the free, voluntary platform.
• CSRD in France: a neighbour that transposed the CSRD by ordonnance n° 2023-1142.
• CSRD in Austria: a German-language neighbour.

What Changes Once the German Bill Is Adopted

The bill would end the CSR-RUG duty for each group from its first draft year: financial years beginning after 31 December 2024 for wave 1, subject to the relief, and financial year 2027 for companies above the new thresholds.

The report content would come from the ESRS, which apply directly as delegated regulations. The revised (simplified) ESRS, Delegated Regulation (EU) 2026/1563, are mandatory for financial years beginning on or after 1 January 2027; what the revised (simplified) ESRS change is set out standard by standard.

When will Germany transpose the CSRD?

No adoption date exists as of 29 October 2026, because the bill is still in committee. Directive (EU) 2026/470 is due by 19 March 2027.

Do German companies report under the ESRS for financial year 2025?

Not under the law in force as of 29 October 2026, the CSR-RUG. The draft would reach back to financial year 2025 for wave 1.

Who may assure a sustainability report under the German bill?

A Wirtschaftsprüfer, vereidigter Buchprüfer or firm registered under the WPO (§ 324e HGB-E); no IASPs.

Can German companies report voluntarily before the bill is adopted?

Yes: § 289d HGB lets a company choose a framework, stating which one or why none. The German Sustainability Code platform for voluntary reports is free, voluntary and not a CSRD transposition.