Questions and answers on the delayed implementation of the CSRD

On 20 December 2024, the Institute of Public Auditors in Germany (IDW) published a question-and-answer paper in connection with the implementation of the Corporate Sustainability Reporting Directive (CSRD) into German law, which is not expected to take place by 31 December 2024.

The CSRD, which regulates sustainability reporting by companies, still has to be transposed into national law as EU law. In July 2024, the German government's draft implementation law was published. The legislative process is not expected to be completed by 31 December 2024 and the law will therefore not come into force before the end of 2024, even though the first companies were already scheduled to report for the 2024 financial year in accordance with the EU directive.

The Q&A paper is based on the IDW members' circular dated 14 November 2024, in which fundamental questions in this context have already been answered.

In its paper, the IDW addresses the following areas for the preparation of non-financial (group) reporting:

• Applicable legal framework,
• Target object of reporting, e.g. application of ESRS,
• Exemption regulations in the group context,
• Other reporting requirements, e.g. the most important intangible resources and the most significant non-financial performance indicators.

The following aspects are highlighted in the area of the audit of non-financial (Group) reporting:

• Assignment,
• Auditing principles based on ESRS,
• Fee Cap.

The answers reflect the IDW's preliminary view on selected questions based on the current state of discussion. The Q&A paper will be updated and supplemented with further aspects as necessary.

The Q&A paper is available on the IDW website.

We explain further information in our KPMG publication "Delayed implementation of the CSRD", particularly for reporting and auditing. We explain the most important consequences and offer clear options for action