Last updated: May 27, 2026. Sustainability reporting in Germany is shaped by German corporate reporting law, EU sustainability reporting rules, and supply-chain due diligence rules. The most important current point is that the framework is in transition: Germany is still implementing the CSRD into national law while the EU has already adopted stop-the-clock and Omnibus simplification changes that alter timing, scope, and reporting burden.
Short answer: German companies should not treat CSRD timing as a simple copy-paste from the original 2022 directive. Companies already subject to Germany's legacy CSR-RUG/NFRD reporting still need to manage non-financial reporting and may be affected by CSRD/ESRS implementation. Wave 2 and wave 3 CSRD obligations were delayed by the EU stop-the-clock directive. The 2026 Omnibus I directive narrows CSRD scope to companies with more than 1,000 employees and above EUR450 million net annual turnover, with special rules for third-country undertakings and a transition exemption for some wave 1 companies falling out of scope. Germany's CSRD implementation bill is still being processed through the Bundestag, and companies should confirm their current obligation against both German law and the amended EU framework.
Who needs to report sustainability information in Germany?
Germany's sustainability reporting obligations can come from several routes:
- legacy CSR-RUG requirements implementing the EU Non-Financial Reporting Directive for certain large public-interest entities;
- the CSRD and ESRS as implemented into German law, with timing and scope affected by stop-the-clock and Omnibus I amendments;
- EU Taxonomy Article 8 reporting for companies that are in scope of the relevant non-financial or sustainability reporting regime;
- the German Supply Chain Due Diligence Act, known as LkSG, for companies with relevant German employee thresholds and supply-chain due diligence obligations;
- financial-market, bank, investor, lender, parent-company, public procurement, or customer requirements; and
- non-German requirements where a German company has EU group, non-EU parent, supplier, securities, or market exposure.
For many German companies and suppliers, the practical question is not only whether a formal sustainability report is legally required. It is also whether a customer, investor, bank, parent company, or tender process is asking for emissions data, supply-chain due diligence evidence, ESRS-style metrics, EU Taxonomy information, or a supplier questionnaire.
Germany's CSRD implementation status
The CSRD should have been transposed into national law by July 6, 2024. Germany missed that deadline, and the European Commission opened infringement proceedings against Germany in September 2024. The German Federal Government later introduced a CSRD implementation bill into the Bundestag. Bundestag materials describe the bill as implementing Directive (EU) 2022/2464 on corporate sustainability reporting as amended by Directive (EU) 2025/794, the stop-the-clock directive.
The German bill is intended to amend many existing laws, including the German Commercial Code, the Securities Trading Act, and auditor regulation. The Bundestag summary states that the Government intends a 1:1 implementation and also plans to transpose the stop-the-clock changes. The same Bundestag materials note that further EU-level changes were already foreseeable and that the substance proposal could not be fully reflected before final EU adoption.
As of late May 2026, the practical takeaway is: Germany's CSRD implementation is not a static regime. Companies should check whether they remain under legacy CSR-RUG/NFRD reporting, whether they are in a wave already reporting or preparing under CSRD/ESRS, whether stop-the-clock changes delay their first CSRD report, and whether Omnibus I removes or changes their expected scope.
EU stop-the-clock and Omnibus I changes
The EU stop-the-clock directive postponed CSRD reporting for companies that would otherwise have had to publish sustainability information in 2026 or 2027, commonly called wave 2 and wave 3 companies. ESMA explains that this put on hold the requirements for undertakings that had not already started reporting.
The later Omnibus I directive, published in the Official Journal in February 2026 and in force from March 2026, goes further. ESMA describes it as including content amendments that reduce CSRD scope, remove sector-specific standards and the listed SME standard, and remove the European Commission's mandate to adopt reasonable assurance standards. Member States must transpose the CSRD-related parts by March 19, 2027.
The Council's final approval announcement says the CSRD scope is narrowed to companies with more than 1,000 employees and above EUR450 million net annual turnover. For third-country undertakings, the updated requirements apply only where the parent has more than EUR450 million net turnover in the EU and the EU subsidiary or branch has more than EUR200 million generated turnover. The same announcement notes a transition exemption for wave 1 companies that had to start reporting from financial year 2024 but fall out of scope for 2025 and 2026.
Companies should therefore avoid relying on older CSRD scope summaries that say the default threshold is more than 250 employees, EUR40 million turnover, or EUR20 million balance sheet total. Those thresholds were central to the original CSRD rollout, but the 2026 simplification package materially changes the analysis.
What ESRS reporting requires
Companies in scope of CSRD report using European Sustainability Reporting Standards, or ESRS. The ESRS are built around double materiality, meaning companies need to consider both impact materiality and financial materiality. They also require disclosures across governance, strategy, impact/risk/opportunity management, and metrics and targets.
For companies that remain in scope, preparation typically covers:
- double materiality assessment and stakeholder input;
- governance and management responsibilities for sustainability matters;
- policies, actions, targets, and metrics for material topics;
- climate change disclosures, including transition plans where relevant;
- Scope 1, Scope 2, and relevant Scope 3 GHG emissions;
- environmental topics such as pollution, water, biodiversity, resource use, and circular economy where material;
- social topics covering own workforce, workers in the value chain, affected communities, and consumers/end-users where material;
- business conduct, anti-corruption, and governance topics; and
- data controls, evidence files, digital tagging readiness, and assurance readiness.
Even companies that are removed from mandatory scope may still be asked for ESRS-style data by larger customers. The EU simplification package is designed to reduce trickle-down effects, but supplier requests are unlikely to disappear entirely, especially for emissions data, human-rights due diligence, and product or service-level information.
EU Taxonomy reporting
The EU Taxonomy is a classification system for environmentally sustainable economic activities. It does not create a standalone sustainability report for every German company, but it connects to existing sustainability reporting obligations. Companies in scope may need to disclose Taxonomy-eligible and Taxonomy-aligned turnover, capital expenditure, and operating expenditure.
In practice, EU Taxonomy work is often data-heavy. Companies need to identify eligible activities, test substantial contribution criteria, assess do-no-significant-harm criteria, consider minimum safeguards, and connect taxonomy results to financial statement line items. Omnibus I and related taxonomy simplification work may change future detail, but companies that remain in scope should still maintain a clear evidence trail for taxonomy decisions.
Supply-chain due diligence under LkSG
The German Supply Chain Due Diligence Act, or LkSG, came into force on January 1, 2023 for companies based in Germany with more than 3,000 employees. Since January 1, 2024, it applies to companies with more than 1,000 employees in Germany. The law requires covered companies to implement due diligence processes for human-rights risks and certain environmental risks in their own business area and supply chains.
The LkSG includes risk management, regular risk analysis, preventive measures, remedial measures, a complaints procedure, documentation, and reporting. Environmental risks are narrower than a full environmental sustainability report and are tied to specified international environmental agreements and human-rights-linked environmental harms.
The reporting part is currently in transition. BAFA's reporting-obligation page states that, against the background of the German Government's September 3, 2025 bill to amend the LkSG, BAFA has completely stopped reviewing company reports under sections 12 and 13 LkSG. BAFA also says submitting a report through a BAFA-provided access is no longer possible. This does not mean all LkSG due diligence duties disappeared. Companies should distinguish between the status of report submission/review and the continuing operational due diligence duties.
What companies should prepare now
German companies should first confirm which obligation is actually driving the work. A legacy CSR-RUG reporter, a large listed group, a company previously expected to be wave 2, a financial institution, an LkSG-covered buyer, and a supplier responding to a customer request will not need the same project.
A practical readiness plan usually includes:
- confirming whether the company is currently reporting under CSR-RUG/NFRD, preparing for CSRD/ESRS, affected by stop-the-clock, or potentially removed from scope by Omnibus I;
- checking group structure, listing status, employee numbers, net turnover, EU turnover, branches, subsidiaries, and parent-company reporting exposure;
- mapping sustainability data owners across finance, legal, risk, operations, facilities, procurement, HR, investor relations, and sustainability teams;
- running or refreshing a double materiality assessment where ESRS reporting or ESRS-style customer data is expected;
- collecting Scope 1 and Scope 2 GHG data, including fuel, refrigerants, electricity, steam, heat, cooling, and renewable-energy evidence;
- screening Scope 3 categories and identifying supplier, logistics, product, procurement, travel, leased asset, and investment data needs;
- documenting boundaries, emission factors, calculation methods, assumptions, exclusions, controls, and evidence files;
- assessing EU Taxonomy eligibility and alignment where relevant;
- reviewing LkSG risk analysis, complaints procedures, supplier engagement, documentation, and remediation processes where relevant; and
- maintaining a decision log on scope, timing, reliefs, and assumptions because the legal framework is changing quickly.
What if you are a supplier or mid-market company?
A German supplier may not be directly in CSRD scope after Omnibus I, but it can still receive requests from customers, investors, lenders, or parent companies. Common requests include GHG emissions data, product carbon footprint inputs, renewable-energy evidence, ESRS-style workforce or supplier data, LkSG due diligence information, EcoVadis or CDP responses, or EU Taxonomy-related activity information.
The first step is to interpret the actual request. If a buyer asks for emissions data or due diligence evidence, the supplier does not necessarily need a full ESRS report. Keslio's supplier request support helps turn the request into a focused response rather than a broad ESG project.
Common mistakes to avoid
- Using old CSRD thresholds without checking Omnibus I. The 2026 EU changes materially narrow scope and change timing.
- Assuming Germany's CSRD implementation is already simple and settled. Germany's implementation process has been delayed and is being handled alongside EU simplification changes.
- Confusing LkSG report-review suspension with removal of all due diligence duties. BAFA has stopped reviewing reports, but companies should still manage operational LkSG obligations unless and until the law changes.
- Ignoring suppliers because of reduced CSRD scope. Larger companies may still need supplier data for emissions, value-chain impacts, due diligence, taxonomy, and customer-specific requirements.
- Leaving Scope 3 and evidence files until the reporting deadline. Value-chain data, methodology choices, controls, and audit trails take time.
How Keslio can help
Keslio helps companies turn German and EU sustainability reporting requirements into practical workstreams, data requests, calculations, and report content. For Germany, this can include:
- applicability checks across CSR-RUG/NFRD, CSRD/ESRS, Omnibus I scope, stop-the-clock timing, EU Taxonomy, LkSG, and supplier requests;
- GHG emissions calculations for Scope 1, Scope 2, and relevant Scope 3 categories;
- data request templates and evidence trackers for finance, operations, facilities, procurement, HR, logistics, and legal teams;
- double materiality and ESRS gap review support;
- EU Taxonomy eligibility and alignment workstream support;
- LkSG due diligence evidence and supplier-information support where relevant;
- sustainability reporting and communications for annual report content, voluntary sustainability reports, or customer-ready disclosures; and
- supplier request support where the reporting trigger comes from a customer, buyer, lender, investor, or parent company.
This guide is not legal advice. If your company is determining formal applicability, German implementation status, CSRD scope, stop-the-clock relief, LkSG duties, EU Taxonomy reporting, exemptions, or interpretation of German or EU law, legal counsel, auditors, company secretarial advisers, or the relevant regulator should confirm the obligation while Keslio supports the ESG data, calculations, reporting, and evidence workstream.
Sources and further reading
- Bundestag summary of Germany's CSRD implementation bill
- Bundestag committee hearing on sustainability reporting
- European Commission page on corporate sustainability reporting
- ESMA sustainability reporting page and Omnibus process summary
- Council of the EU announcement on Omnibus I final approval
- DRSC note on CSRD amendments and German implementation status
- European Commission page on the EU Taxonomy
- BAFA page on LkSG reporting obligations
- BMUKN page on the German Supply Chain Due Diligence Act
