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ESG Reporting in Germany: A Complete Guide

ESG reporting in Germany is essential for companies to stay compliant and commit to sustainability. Learn how ESG Flo can help collect, manage, and report ESG data.
by 
Chiara Meacci
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August 27, 2024
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In today's business landscape, Environmental, Social, and Governance (ESG) reporting is no longer just a buzzword; it's becoming a critical aspect of corporate transparency and accountability.

For companies operating in Germany, understanding the “ins and outs” of ESG reporting is essential for staying compliant and demonstrating a commitment to sustainability.

Is ESG reporting mandatory in Germany?

Yes, ESG reporting has been mandatory for certain companies in Germany since 2017, following the implementation of the CSRD Implementation Act.

This requirement applies to large, capital market-oriented companies, insurance companies, financial service providers, credit institutions, and cooperatives. However, for many other companies, ESG reporting remains voluntary until the end of 2024.

Possible standards for ESG reporting in Germany

One of the complexities of ESG reporting in Germany is the absence of a universal format. Companies have the flexibility to choose from various German and European standards. Two of the most popular frameworks at the national level are:

  • German Sustainability Code (DNK): A comprehensive standard widely adopted by German companies.
  • Global Reporting Initiative (GRI): An internationally recognized framework that provides guidelines for sustainability reporting.

The European Union is introducing mandatory sustainability reporting standards for companies.

These standards, developed by the European Financial Reporting Advisory Group (EFRAG), will apply to all businesses covered by the Corporate Sustainability Reporting Directive. While these standards will provide a framework, it's important to remember that every company's ESG situation is unique.

Each company must conduct a materiality analysis to determine the standards that best fit its industry and specific circumstances.

Which companies need to engage in ESG reporting?

As of now, ESG reporting is obligatory for large, capital market-oriented companies in Germany. However, starting from January 1, 2025, this requirement will extend to all large companies that meet at least two of the following three criteria:

-Minimum of 250 employees

-Net sales of €40 million or more

-Total assets of €20 million or more

This expansion will significantly impact a broader range of businesses, including limited liability partnerships, insurance companies, and banks. By January 2026, the criteria for companies with a capital market-oriented structure will tighten further, lowering the thresholds to 10 employees, €700,000 in sales revenue, and €350,000 in total assets.

It's worth noting that medium-sized, small, and micro companies without a capital market orientation will remain exempt from mandatory ESG reporting for the time being.

Steps to creating an ESG report for a company in Germany

  • Start by outlining your company's approach to ESG, focusing on the areas most relevant to your operations.
  • Collect information on how your company affects the environment, treats people, and is run.
  • Decide which numbers best show how well your company is doing in these areas.
  • Pick the right reporting guidelines for your business
  • Compile the collected data into a comprehensive and transparent ESG report, ready for submission and publication.

Final thoughts

As ESG reporting continues to evolve, staying informed about regulatory changes and best practices is crucial for companies in Germany. Whether your company is already subject to mandatory reporting or preparing for future obligations, understanding the requirements and available frameworks will help you navigate this complex but essential aspect of modern business.

ESG Flo can help companies in Germany with ESG reporting by providing a comprehensive solution to establish a robust, auditable ESG data infrastructure. ESG Flo's platform enables companies to efficiently collect, manage, and report ESG data, ensuring compliance with international and European standards such as GRI, SASB, and ESRS.

By streamlining the data management process, ESG Flo allows companies to focus on improving their sustainability performance while ensuring transparency and accuracy in their ESG reporting.

Sources:

https://iclg.com/practice-areas/environmental-social-and-governance-law/germany

https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en

https://www.fin-connect-nrw.de/en/studies/what-does-the-corporate-sustainability-reporting-directive-csrd-require

https://www.lw.com/admin/upload/SiteAttachments/How-Germany%E2%80%99s-New-ESG-Law-Will-Affect-Suppliers-Globally.pdf

https://www.dentons.com/en/insights/articles/2023/august/31/german-government-requires-enhanced-esg-responsibility

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