Are the requirements of CSRD transposed? If yes, what was the implementation date and what is the name of the legislation?
Transposition not yet complete – The European Commission opened infringement proceedings on 26 September 2024. Draft legislation available.
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 March 2026 coalition amendment to the draft bill incorporates the Omnibus I thresholds. Once adopted, the reporting obligation will be determined solely by whether a company exceeds both cumulative thresholds: >1,000 employees and >EUR 450 million net turnover, regardless of listing status. Listed SMEs will no longer be in scope for mandatory reporting (though voluntary reporting under the VSME framework remains available).
Note: All timelines below are subject to adoption of the bill, which has not yet occurred.
The sustainability reporting obligation is phased in as follows:
- 2026: for large companies that are either listed or operate as credit institutions or insurance companies, with more than 1,000 employees and net turnover exceeding EUR 450 million, for 2025 financial year
- 2028: all other undertakings exceeding >1,000 employees and >EUR 450 million net turnover, for 2027 financial year
- 2029: for third‑country companies with net turnover exceeding EUR 450 million in the EU and exercising control over a German subsidiary exceeding the thresholds, or having a branch generating EUR 200 million+ turnover, whose reporting obligation remains for financial years starting 1 January 2028 or later
Do any enforcement provisions, such as sanctions or penalties exist under local law for non-compliance with CSRD?
Yes. The draft transposing legislation provides for enforcement and sanctions, including administrative fines. Final provisions are subject to adoption of the bill.
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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