New Attempt to Implement the CSRD in Germany Launched – Practical Implementation Required

On September 3, 2025, the Federal Cabinet approved a new draft bill intended to transpose the EU Corporate Sustainability Reporting Directive (CSRD) into German law. The previous federal government had already submitted a draft bill to implement the CSRD, but the legislative process was not completed at that time.

The new draft also aims, in principle, for a 1:1 transposition, meaning that no requirements beyond those of the European draft are to be imposed on companies. Large capital-market-oriented companies that were already subject to the previous regulation must submit their first reports for the 2025 fiscal year. However, a transitional solution has been included for companies with between 501 and 1,000 employees. Since these companies are expected to fall outside the scope of the CSRD as part of the Omnibus Initiative currently under negotiation, the draft provides for exempting these companies from reporting for the 2025 and 2026 fiscal years. The two-year deferral of the reporting obligation for newly subject companies under the “stop-the-clock” provision is also already included.

However, maintaining the “preparation-based approach” for electronic reporting starting in 2026 entails a disproportionate bureaucratic burden. This places a significant additional burden on companies without offering any corresponding benefit. It is therefore imperative to move away from the “preparation solution” for electronic reporting. The BDI also urges a reconsideration of whether a German implementation of the CSRD is actually necessary in 2025 and before the conclusion of the omnibus negotiations. Further BDI demands can be found in the BDI’s position paper on the German implementation of the CSRD.

Revision of the CSRD as Part of the EU Omnibus I – Making Sustainability Reporting More Targeted

The European Commission’s ongoing Omnibus initiative offers a unique opportunity to achieve a targeted revision of sustainability reporting and a significant reduction in the administrative burden on companies. On June 23, 2025, the Council’s negotiating mandate for Omnibus I was initially adopted. The Council’s position addresses many of the demands outlined in the BDI’s position paper. On June 12, 2025, the rapporteur for the European Parliament’s lead committee, the Committee on Legal Affairs (JURI), also presented his draft report on the EP’s position. This report includes many of the BDI’s demands and is generally welcome. The vote in the JURI Committee will take place on October 13, followed two weeks later by the vote in plenary. Subsequently, the trilogue will take place together with the European Commission. A conclusion is expected by the end of this year. You can find our specific demands in the BDI position paper on the revision of the CSRD as part of the EU Omnibus I.

Revision of the ESRS Sustainability Reporting Standards – Focusing on Data Points Relevant to Management Decision-Making

The specific reporting standards, the European Sustainability Reporting Standards (ESRS), are also to be simplified as part of the Omnibus initiative. EFRAG is to submit a technical recommendation on the revision of ESRS Set 1 to the European Commission by November 30, 2025. The BDI participated in the consultation on the recommendation and generally welcomed the 57% reduction in mandatory reporting data points—based on each company’s individual materiality analysis—and submitted additional proposals for simplification.