DIHK on the Implementation of the CSRD: Improve the Draft and Relieve Companies

The German government is implementing the European guidelines for sustainability reporting (Corporate Sustainability Reporting Directive, CSRD) into national law. The German Chamber of Commerce and Industry (IHK) sees considerable need for improvement to avoid overloading companies.

The new law to implement the CSRD will impose extensive reporting obligations on many companies. However, there is significant uncertainty in the business community regarding the scope, data requirements, and practical implementation. The German Chamber of Commerce and Industry (IHK) criticizes that many European requirements, already considered disproportionate, are now to be transferred unchanged into German law. Realistic transition periods and practical guidelines are crucial for the competitiveness and planning reliability of businesses.

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Background

The CSRD will in future require significantly more companies to report on sustainability—directly and indirectly through supply chains. Meanwhile, the EU Commission, Council, and Parliament are already working on simplifying the rules and revising the European Sustainability Reporting Standards (ESRS) due to the disproportionate efforts faced by companies. However, the German draft law remains bound to the existing guidelines. Small and medium-sized enterprises (SMEs) are particularly affected through the "trickle-down effect" as they receive extensive data requests from reporting business partners. High implementation efforts, unclear audit standards, additional burdens from the ESEF format, and questions about handling business secrets create further uncertainties. The German Chamber of Commerce and Industry (IHK) emphasizes that reporting obligations without sufficient transitions are generally disproportionate.

What Companies Should Know

Companies must collect comprehensive data from the entire value chain – including from suppliers who are not obligated to report themselves.
The implementation requires new processes: materiality analysis, data systems, responsibilities, and internal controls.
The obligation to prepare reports in the ESEF format presents companies with technical and organizational challenges for the first time.
Extensive information on Scope-3 emissions, material details, and intangible resources is often difficult to obtain.
Businesses should clarify early whether external consultation, certifications (such as EMAS, ISO), or digital tools can support their reporting obligations.

DIHK’s Demands

Create transitional rules: At least a multi-year introduction phase with reduced or suspended sanctions, so that companies can realistically implement the new reporting requirements.
Fundamentally simplify CSRD and ESRS: Quickly revise the EU guidelines and significantly reduce the amount of mandatory data points.
Limit the trickle-down effect: Legally define what data large companies can request from SMEs and establish boundaries to prevent disproportionate burdens.
Ease the ESEF obligation: Separate technical format requirements from content reporting obligations to avoid unnecessary complexity.
Create legal certainty: Legally clarify rules for consolidation, exemptions, and handling of business secrets.