Are the requirements of CSRD transposed? If yes, what was the implementation date and what is the name of the legislation?
Not yet transposed / in draft. Transposition not yet complete - The European Commission opened infringement proceedings on September 26, 2024.
Has the local legislation extended the scope of the CSRD, by adding any additional requirements or going beyond the Directive in any way?
No.
How does the transposition affect different types of companies? Are there specific provisions for different sizes or types of companies, such as SMEs versus large enterprises?
The sustainability reporting obligation is phased in as follows:
- Wave 1 (from FY 2025, first reports in 2026): Applicable to large companies that are either listed or operate as credit institutions or insurance companies, with more than 1,000 employees.
- Wave 2 (from FY 2027, first reports in 2028): Applicable to other large companies, with obligations postponed in line with the EU-wide timeline.
Do any enforcement provisions, such as sanctions or penalties exist under local law for non-compliance with CSRD?
Yes.
If the CSRD has not yet been transposed, what steps have been taken towards implementation?
Transposition process started. On 3 September 2025, the German cabinet adopted the new government draft bill for implementing the CSRD. It also takes into account the Stop-the-Clock Directive. On 30 March 2026, the government published an amendment to the draft bill that includes the amendments introduced by the Omnibus I Directive. This draft has not yet been passed into law.
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