New draft bill on the CSRD Implementation Act published

On 10 July 2025, the Federal Ministry of Justice and Consumer Protection published a new draft bill on the implementation of the Corporate Sustainability Reporting Directive (CSRD) (draft law on the implementation of Directive (EU) 2022/2464 with regard to corporate sustainability reporting as amended by Directive (EU) 2025/794).

The deadline for implementing the CSRD, which came into force in January 2023, had already expired on 6 July 2024. The legislative process that began with the draft bill of 22 March 2024 (see EAN 14/2024) and the government bill of 24 July 2024 (see EAN 34/2024) was no longer completed within the 20th legislative period and must therefore begin again in 2025 due to the change of government.

The new draft bill now available already takes into account the postponement of the introduction of sustainability reporting for those companies that would have had to report for the first time on the 2025 or 2026 financial year under the previous version of the CSRD (so-called "2nd wave" and "3rd wave") as a result of the so-called "Stop-the-Clock Directive" ((EU) 2025/794, see EAN 19/2025). For these groups of companies, the start of sustainability reporting will be postponed by two years.

The substantive simplifications and simplifications proposed by the EU Commission in the First Omnibus Package on 26 February 2025, including the proposed changes to the scope of application (see EAN 10/2025), cannot yet be transposed into national law as they have not yet been finally adopted at EU level. According to the current draft bill, the German government expects that - subject to the outcome of the European legislative process - the legal framework will be significantly simplified, especially for companies in the 2nd and 3rd wave, before the time of their first-time reporting and that a significant number of companies will be released from the sustainability reporting obligation.

As a reduction in the scope of application is also to be expected for 1st wave companies, which according to the new draft bill must report for the first time on financial years beginning after 31 December 2024, the current draft bill proposes to exempt 1st wave companies with 501 to 1,000 employees from reporting on the 2025 and 2026 financial years. This is intended to prevent these companies from only being required to report for a very short transitional period.

The draft bill of the implementation law is available here.