BDA AGENDA 23/25 | Special feature of the week | November 13, 2025

Wait for Omnibus I procedure first – then implement new CSRD rules

The business community is clearly committed to sustainable corporate governance and appropriate reporting. Reporting requirements must be clear, proportionate, and practicable. The current draft law on the implementation of the CSRD comes at an inopportune time. While the EU is comprehensively revising the directive and standards (ESRS), national implementation now would lead to double the effort: reporting in 2025 according to old requirements that have been criticized as excessive – and according to new standards from 2026 onwards. This is neither efficient nor in the public interest.

The draft law should therefore be postponed until the Omnibus I package has been finalized. The EU Commission also considers a revision to be urgently necessary and is unlikely to pursue infringement proceedings. Companies need legal certainty: the new CSRD should only apply to financial years after December 31, 2025. Anything else would lead to unnecessary costs and uncertainty.

If it is implemented nonetheless, it should be implemented 1:1 without “gold plating.” Additional national obligations would further increase bureaucracy. The burdens are already enormous: for the approximately 3,900 companies affected, the average annual compliance costs are expected to be around €110,000 – and in many cases significantly more. Added to this is the trickle-down effect for SMEs in the supply chains. Therefore, all opportunities must be exploited to make the requirements as unbureaucratic as possible. This includes the prompt abolition of the double reporting obligation in the LkSG and the introduction of a disclosure solution instead of an impractical “preparation solution.” Tightening the requirements would jeopardize competitiveness.

On the positive side, the planned increase in the threshold to 1,000 employees will ease the burden on many companies. However, if the EU decides on a higher threshold, Germany must follow suit in order to avoid competitive disadvantages. Equally important are practical standards that take data protection and feasibility into account, as well as support services for companies that are required to report for the first time. The federal government should take action here – for example, by providing free advice and clear guidelines.

The digitization of reports must not be overly burdensome either: tagging in ESEF format incurs high costs and requires lead time. It makes sense to wait until 2026 to introduce it. In addition, the reports must be audited on an ongoing basis with limited audit assurance, as proposed by the EU itself. Anything else would create additional burdens without added value.

Conclusion: Sustainability reporting must not become a bureaucratic monster. The current approach is to wait for the European reforms and then start a lean, practical implementation. Only in this way can the transformation to a sustainable economy remain realistic and competitive.