We support you in complying with the CSR directive
CSR Reporting Obligation
The non-financial reporting obligation or CSR reporting obligation has been in place since 2014. There were no structural requirements from the legislator, but the recommendation to adhere to existing reporting standards (e.g. GRI or UNGC) when preparing the report. Companies should provide information on each of the five declared aspects (environmental issues, employee issues, social issues, human rights and corruption) as well as on other material issues.
Soon, the CSR reporting requirement will be replaced by the CSRD – Corporate Sustainability Reporting Directive. At the end of 2022, the CSRD standards will be given to the European Commission and subsequently transposed into national law by the EU member states. The current plan is for a phased introduction starting in January 2025 (reporting for fiscal year 2024). Find out about the changes now here.
At DFGE, we can help you capture and validate the essential information for the CSR reporting requirement as well as the upcoming CSRD. As a complete package or modular for your management report, your annual report or for your non-financial report on your website.
- DFGE Blogpost Overview CSR Reporting Obligation (German)
- Legislative text CSR Directive
- Federal Government – CSR in Germany
- IDW – Reporting of non-financial information
As an accredited provider, we conduct a review or external audit of your CSR report in accordance with the specifications of the AA1000 international auditing standard for sustainability reports.
This guarantees an independent and objective reflection of your report and blind spots can be identified. In addition, by commissioning an external audit or review, your supervisory board can ensure that the legal requirements for non-financial reporting are met.
- First review
- Short report with feedback
- Follow-up call
- Error prevention
- Start meeting with project introduction
- Review of existing documents
- Preparation of responses / reports
- Creation of your CSR roadmap
Taking into account all requirements of the CSR reporting obligation, the chosen standards and other requirements on your part, we provide you with a turnkey sustainability report in accordance with GRI or UN Global Compact specifications.
This reduces your internal effort to a minimum and allows you to focus on the continuous improvement of your identified sustainability areas.
Our team takes care of the preparation and critical support of the reporting process according to the requirements of your company and the chosen reporting standard.
We support you in the preparation of your non-financial report – from the materiality analysis to determine the required topics, through the involvement of your stakeholders to internal data management.
Our team ensures holistic reporting and comes to a result quickly and in a target-oriented manner in intensive coordination with you. This ensures efficient and timely reporting.
- Individual consulting
- Development of an improvement strategy
- Implementation and concrete realization
Why you should turn to DFGE for CSR reporting requirements
- Many years of experience in preparing a sustainability report in accordance with GRI and UN Global Compact requirements.
- Save time and effort and use our expertise
- Ability to adapt your report and sustainability management around the SDGs with our help
- We can help you to make your supply chain accountable and support the companies concerned in the preparation of a sustainability report
- Holistic customer support through our Sustainability Intelligence approach
- We see ourselves as a coach, consultant and service provider – to minimize resources and effort on your side and still publish a sustainability report in compliance with the CSR directive.
- Nor are we an advertising agency that makes your data prettier. Our roots are in research and this is how we still work today
For whom and why?
The CSR reporting obligation was adopted by the EU Parliament in 2014 as the so-called CSR Directive, which was transposed into national law by the German Federal Government in spring 2017.
According to the CSR reporting obligation, capital market-oriented corporations (e.g. AG, KGaA, SE) and capital market-oriented limited partnerships (e.g. certain GmbH & Co. KGs), as well as financial services, insurance and credit institutions must report information on non-financial aspects under certain conditions (as of the beginning of the 2017 financial year) in order to comply with the CSR reporting obligation. A company is required to report if it meets the following requirements:
the company has more than 500 employees
the balance sheet total is higher than €20 million or sales are higher than €40 million
Information must be provided on each of the five declared aspects (environmental issues, employee issues, social issues, human rights and corruption) as well as on other material issues. There are no structural requirements on the part of the legislator, but it is recommended that existing reporting standards (e.g. GRI or UNGC) be followed when preparing the report.
The report can be published as part of the management report, as a separate section in the annual report or as a separate non-financial report on the website (no later than four months after the balance sheet date).
Increased transparency vis-à-vis key stakeholders of the respective company
More intensive examination of non-financial topics and aspects by affected companies
Early identification of risks (e.g. human rights violations within the company’s own supply chain)
With regard to the content requirements, the legislator was not too specific. First, the business model must be presented. In addition, the law explains the five areas of environmental concerns, employee concerns, social concerns, human rights and corruption. Information is required on each of these aspects. The level of detail required for each of these declarations depends on the extent to which it is relevant for understanding the course of business, the development of the company and the impact of the business activity (for non-financial dimensions). If other topics (e.g. consumer issues) are material, information on these must also be provided.
In addition, concepts relating to due diligence processes, results of the concepts, risks, non-financial performance indicators and also negative dimensions/errors must be reported. Individual matters do not have to be reported on, provided the company gives a clear reason for this and describes it (e.g. trade secret, factor hindering competition, no clear strategy, …).
The law does not specify the structure of the report, i.e. companies are free to design their reports as they wish. However, it is recommended to follow existing established frameworks (e.g. GRI or UNGC).
- The materiality of the published information in accordance with the HGB is of central importance.
- If SMEs function as suppliers of a large company within the meaning of the NFI Directive, they can also be included in a reporting process after being requested to do so by an affected company
- Subsidiaries are exempt from the reporting obligation if the parent company publishes a non-financial report whose indicators relate to the entire group; in this case, the subsidiaries must nevertheless collect information and data on CSR activities in order to make them available to the parent company for reporting purposes
- The fulfillment of the criteria refers to the entire Group (parent company including all subsidiaries) and is not considered in isolation.
- In future, the supervisory board of the respective company must examine the content of the report on non-financial information in accordance with sections 170 and 171 of the German Stock Corporation Act (AktG). As this requirement represents a major challenge for supervisory boards, external auditors can be engaged to assist or review the content. According to the law, a content review by third parties is not normally necessary
- Penalties of up to €10 million or 5% of total annual sales may be imposed for non-compliance with the reporting requirement