Sustainability reporting (CSRD)

CSRD nach Omnibus ILegal position as of 12 October 2026

Basis: CSRD nach Omnibus I
Threshold: over 1,000 employees and EUR 450 million
Penalty: national implementation pending
Source: Omnibus-Update zu CSRD und CSDDD
last checked 12 October 2026 · review cycle monthly

What is required

Sustainability statement within the management report under the ESRS, with a double materiality assessment, value chain disclosures and external assurance.

What has to be done

one-offCarry out a double materiality assessment and document the approach so it can be followed.
one-offSet up data collection for the ESRS datapoints in the company and across the value chain.
annualPrepare the sustainability statement as a separate section of the management report.
annualTag the report in the single electronic reporting format and publish it.
annualCommission external assurance at the limited assurance level.

Stages over time

Listed, already in scope

1 January 2024Reporting duty for large listed companies

Companies already reporting under the first wave stay in scope.

All companies in scope

1 January 2027First reporting year
1 January 2028First report

Omnibus I raised the threshold; the German implementing act was still pending at the stated legal cut-off date.

Criteria checked

Limited liability legal form
More than 1,000 employees
Turnover above EUR 450 million
Listed on a regulated market

Check this for your own company

Legal position as of 12 October 2026All nine regimes