CSRD Implementation Act: Current Status, Scope of Application, and Deadlines

The European Corporate Sustainability Reporting Directive (CSRD) requires companies to engage in more comprehensive and standardized sustainability reporting. However, its national implementation in Germany has been delayed for over two years now. The CSRD Implementation Act has not yet been passed, and at the same time, its scope of application has been significantly narrowed by the European Omnibus Package. In this article, you’ll learn where the process currently stands, who it will affect, and what you can start preparing for right now.

The CSRD Directive in a Nutshell

The CSRD requires companies to provide detailed reporting on environmental, social, and governance (ESG) factors and extends the reporting requirements of its predecessor, the NFRD, to a significantly larger number of companies. The goal is to increase transparency for investors, customers, and other stakeholders. The substantive reporting standard, the European Sustainability Reporting Standards (ESRS), is directly applicable as a delegated act of the EU and does not require separate national implementation. Only the organizational framework—that is, who reports, when, and how audits are conducted—must be transposed into national law by each member state. This is precisely the part that Germany has been working on since 2024.

Why the German implementation is taking so long

The deadline for transposing the CSRD into national law expired on July 6, 2024. The European Commission has therefore launched infringement proceedings against Germany and 16 other member states.

Regulatory Roadmap in Germany:

• March 22, 2024: First draft bill from the Federal Ministry of Justice
• July 24, 2024: The Federal Cabinet approves a government bill
• September 26–27, 2024: First reading in the Bundestag and deliberations in the Bundesrat
• February 2025: Federal election. The bill lapses under the principle of discontinuity and must be reintroduced in its entirety in the new Bundestag.
• July 10, 2025: New draft bill from the Federal Ministry of Justice
• September 3, 2025: The Federal Cabinet approves the new government bill
• March 18, 2026: The European amending directive (EU) 2026/470 enters into force, significantly reducing sustainability reporting requirements (the so-called “Omnibus” package)
• March 31, 2026: The governing coalition parties, the CDU/CSU and the SPD, introduce a joint amendment to bring the government’s draft bill into line with the new EU requirements
• April 13, 2026: Public hearing before the Bundestag’s Committee on Legal Affairs

Current Status: According to the most recent available source (as of August 2026), the law has still not been enacted. It is expected to take effect sometime in 2026.

Changes to the Scope of Application Resulting from the Omnibus Package

The original government draft was still based on the old, broader CSRD thresholds. The Amending Directive (EU) 2026/470 (in effect since March 18, 2026) has structurally altered the scope of application, not merely postponed it:

Among the “first-wave” companies that have thus far issued a non-financial statement in accordance with Section 289b or Section 315b of the German Commercial Code (HGB), two groups can be distinguished.

Above the new thresholds: Companies with more than 1,000 employees and net revenue exceeding €450 million remain subject to reporting requirements. The amendment proposed by the CDU/CSU and SPD parliamentary groups on March 30, 2026 (Committee Document 21(6)73) provides for initial application for reporting periods beginning after December 31, 2024—that is, as early as the 2025 fiscal year. The IDW criticized this de facto retroactive application on April 7, 2026; other experts recommended during the hearing on April 13, 2026, that the 2025 reporting year be excluded. It remains to be seen how the Bundestag will rule.

Below the new thresholds: Companies with 501 to 1,000 employees or net revenue of up to €450 million will be permanently excluded from the scope of application starting with the 2027 fiscal year. For the fiscal years 2025 and 2026, Directive (EU) 2026/470 allows member states to exempt them from the reporting requirement. The amendment makes use of this option. This will not become binding until the law is enacted.

For both groups, the German implementing law thus determines the fiscal years 2025 and 2026. By contrast, the first reporting year—2027—for the newly covered large companies follows directly from the EU directive and is determined independently of the national procedure.

Overall, approximately 85 to 90 percent of the companies originally covered by the Omnibus Act are exempt from the requirement.

When does the CSRD take effect, and why is the implementing law almost irrelevant in this context?

The official obligation for German companies to implement the CSRD stems from the national implementation law. However, waiting for this law poses a significant risk: The scope of application and the timing of the first reporting for companies newly covered starting in 2027 are already directly determined by the amended EU directive, regardless of the status of national implementation. Waiting for the implementing law only shortens these companies’ own preparation time—not the deadline itself. An exception applies to the “first wave” described below: For these companies, it is indeed the German implementing law that will ultimately determine whether or not they are exempt for 2025/2026.

The timeline leaves no room for further delays: Financial years beginning on or after January 1, 2027, must be reported, with publication in 2028. Until the national law is enacted, companies that are already subject to reporting requirements (public interest, more than 500 employees) will continue to be governed by the previous legal framework under the CSR Directive Implementation Act (CSR-UIG) of 2017.

What Remains Important in the Draft Bill, Despite Changes to Its Content

Regardless of the exact scope of application, the draft contains several key points that remain relevant in practice:

Audit of the Sustainability Report. The audit will remain a limited-assurance audit; the subsequent tightening of requirements—from limited assurance to reasonable assurance—envisaged in the original CSRD text was removed with the Omnibus Package. We describe in detail who is authorized to conduct audits, what exactly is audited, and what auditors rely on in practice in our article on the audit of sustainability reporting.

Inclusion in the Management Report. In the future, the sustainability report must be included in a clearly identifiable section within the management report. A separate publication is no longer planned.

Double materiality analysis. It remains the methodological core of the CSRD and is worthwhile regardless of the status of national implementation. Companies that begin their materiality analysis now will not lose any time when the CSRD finally takes effect.

What Companies Should Do Now

Even without a final law, it’s worth preparing for sustainability reporting: First, the dual materiality analysis remains just as relevant as ever. Second, getting a head start allows time for thoroughly documented processes rather than a rushed, last-minute implementation. Third, beyond the requirements of the law, there are many stakeholders who expect sustainability reporting.

Use the current thresholds to determine whether and when your company is likely to be affected, and actively monitor the legislative process as details may still change before the legislation is finally enacted.

For a more in-depth look, check out our articles on ESRS sustainability aspects, ESRS-xBRL tagging, and why mandatory sector-specific ESRS standards were eliminated.

CONSUST supports you in preparing for sustainability reporting and throughout the reporting process. In our white paper , “Implementing CSRD with Confidence: Four Phases to Your First Report for 2027,” you’ll find a complete roadmap with milestones, a maturity assessment, and the six most common mistakes in first-time reporting projects. Contact us for a no-obligation consultation.