Publication

The German Government Draft CSRD Implementation Act

August 2024
Region: Europe
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The Corporate Sustainability Reporting Directive (CSRD) has required EU Member States to transpose the directive into national law by 6 July 2024. All CSRD requirements are to be transposed into German law through revisions of various laws based on the final CSRD transposition act.

Accordingly, in addition to the extensive amendments to the German Commercial Code (HGB), the draft CSRD Implementation Act (CSRD-UG-E), which was adopted by the German cabinet on 4 July 2024, proposes corresponding alterations to other laws, including the German Stock Corporation Act (AktG), the German Cooperatives Act (GenG), the German Securities Trading Act (WpHG), the German Auditors Ordinance (WPO) and the German Supply Chain Due Diligence Act (LkSG).

The new reporting obligation is to be introduced in Germany in stages. In the initial financial year of 2024, the obligation to report on sustainability will apply solely to large capital market-oriented companies with a workforce of over 500 employees. Subsequently, other groups of companies will be incorporated on a rolling basis until 2028.

Our experts look at board liability, group reporting, audit requirements under the German Government Draft CSRD Implementation Act alongside explanations regarding the transposition made by the German Ministry of Justice.