The introduction of the Corporate Sustainability Reporting Directive (CSRD) in Germany is facing unexpected challenges: A government draft is available, but the legal implementation could not be completed by the end of 2024. Now the CSRD Implementation Act is to be passed and come into force in 2025. This creates uncertainties for many companies that are to be subject to reporting requirements. In this article, you will learn everything you need to know about the current situation and receive practical recommendations for action.
Current status of CSRD implementation
The CSRD has not been successfully implemented in German law by the end of 2024. Now, the CSRD Implementation Act must be passed in 2025 before it can come into force.
What does this mean legally?
The previous sustainability reporting rules will continue to apply for the 2024 financial year. Public-interest entities with more than 500 employees that were already required to prepare a non-financial report under the previous regulation will report under the existing rules for the 2024 financial statements.
Can companies apply the new standards voluntarily?
Yes! Despite the delay, companies can already voluntarily apply the European Sustainability Reporting Standards (ESRS). This offers a strategically valuable opportunity to make good use of the preparations already made for a CSRD-compliant report and to adapt to the upcoming requirements at an early stage.
What are the recommendations for companies?
Continue preparation for the CSRD
Although the introduction of the CSRD has been delayed, it has by no means been cancelled. Implementation is expected to take place in 2025, in line with EU requirements, as soon as the Bundestag has passed the relevant legislation. If this is achieved in 2025, there will be a false retroactive effect and the reporting requirement will apply from 1 January 2025. Companies should therefore continue to work hard on preparing their reporting in accordance with ESRS from the 2025 financial year onwards.
Make good use of existing processes
Companies that have already taken the first steps should continue and deepen them. Why is this important?
- Adoption in 2025 is a serious possibility.
- If the decision is awaited, the remaining time is no longer sufficient to set up valid reporting.
- In addition to their own reporting obligations, there are de facto reporting obligations from the supply chain and for bank discussions.
Orientation towards the IDW questionnaire
The Institute of Public Auditors in Germany (IDW) has published an extended questionnaire. Companies with reporting requirements can use this as a guideline for their reporting and internal processes. The main topics covered are:
- Legal framework and content of non-financial reporting,
- Requirements and practical implementation,
- Report and examples of audit notes.
With these guidelines, companies can optimise existing reporting processes and eliminate weaknesses.
Our recommendation
The delay in implementing the CSRD in Germany gives companies additional time to optimise their reporting. Use this time proactively:
- Identify weaknesses in existing processes.
- Optimise internal structures and reporting systems.
- Prepare for the new requirements in good time.
We support you on your way
ACCONSIS has already voluntarily prepared its own sustainability report based on the currently valid CSRD standards, in addition to numerous consulting projects for clients. This means that we have practical solutions from medium-sized companies for medium-sized companies and offer individual consulting for your company. Contact us today and benefit from our expertise!
Your ACCONSIS contact

Kerstin Weidenbach-Koschnike
Diplom-Kauffrau
German CPA, Tax Consultant
Managing Director of ACCONSIS
Service phone
+49 89 54 71 43
or via email
k.weidenbach-koschnike@acconsis.de