Germany finds itself in an unusual position on CSRD in 2026. The country still hasn’t completed national transposition, but the EU framework it needs to implement has already changed significantly through the Omnibus package.
That means two things:
- Companies should not rely on older CSRD plans or assume that the original scope and reporting timelines still apply without reassessing them against the revised EU rules and the status of German implementation.
- Some businesses may now fall outside the revised requirements, while others still need to prepare for rules that are evolving at both the EU and national levels
In this guide, we break down the current state of play, who needs to comply, the key timelines, and how companies can prepare.
CSRD in Germany in 2026: The state of play
As of September 2026, Germany still hasn’t completed the transposition of the CSRD into national law, more than two years after the original July 2024 deadline.
What complicates things further is that the EU framework Germany needs to implement has changed with the Omnibus package, which has narrowed the main CSRD scope and altered the rules that apply from 2027.
The reporting standards are changing, too. The European Commission published a delegated act on revised ESRS and voluntary sustainability reporting standard in July 2026 that aims to simplify and streamline sustainability reporting requirements. It will apply to financial years beginning on or after 1 January 2027 once it enters into force.
The current picture looks like this:
| Settled at EU level | Still progress |
| Revised CSRD scope and thresholds | Germany’s national transposition |
| New main scope applying from FY2027 | How the updated EU rules are reflected in German law |
| Revised ESRS adopted by the Commission | Publication and legal effect of the revised ESRS |
That makes 2026 a year to reassess scope, timelines, and reporting preparations against the latest EU position while keeping a close eye on German implementation.
What is the CSRD and why does Germany need to implement it?
The Corporate Sustainability Reporting Directive (CSRD) is the EU framework for sustainability reporting by companies within scope.
In practice, it requires companies to report on areas including:
- Environmental, social and governance matters
- Risks and opportunities linked to sustainability
- The impacts the business has on people and the environment
- Policies, targets, actions and performance
- Relevant sustainability metrics and supporting evidence
Companies report under the European Sustainability Reporting Standards (ESRS), which set out the disclosure requirements. A central principle is double materiality: companies assess both how sustainability issues affect the business and how the business affects people and the environment.
Because the CSRD is an EU directive, each member state needs to transpose it into national law. Germany was required to do this by 6 July 2024, but the deadline passed without full transposition.
That delay matters because German legislation determines how the EU requirements operate within the country’s existing company and reporting laws. With the EU framework now revised through the Omnibus package, Germany also needs to reflect those changes as it completes the process.
As of September 2026, the priority is to understand what’s already settled, what still depends on German implementation and what action makes sense now.
Which German businesses have to comply with the CSRD, and when?
The biggest change for German companies is the narrower CSRD scope. A business that expected to report under the original rules may no longer meet the revised thresholds.
At EU level, the current timetable looks like this:
| Reporting period | EU-level position |
| FY2024–2026 | The original first reporting cohort remains relevant. Member states can provide relief for FY2025–2026 to companies falling outside the revised scope. |
| From FY2027 | The revised main scope applies to companies with net turnover exceeding €450m and 1,000 employees. |
| From FY2028 | Separate reporting requirements begin for qualifying non-EU groups with significant EU activity. |
These dates need to be read alongside Germany’s unfinished transposition process. The EU timetable is clear, but Germany still needs to complete the national legislation that gives effect to the revised requirements domestically.
Under the revised CSRD rules, both thresholds apply. A company with more than 1,000 employees but turnover below €450 million, for example, wouldn’t fall within the main scope on those criteria alone.
If you assessed your CSRD scope against the older thresholds, you need to check it again.
What should German companies do about CSRD now?
With Germany’s transposition still unfinished and the EU rules now revised, the priority is to work within the existing framework rather than older CSRD plans.
1. Reassess whether you’re still in scope
If your original assessment used the previous CSRD thresholds, revisit it against the revised requirements. Some companies that expected to report may now fall outside the main scope.
Group structure and consolidated figures can also affect the assessment, so companies should document how they reached their conclusion.
2. Separate EU-level changes from German implementation
The Omnibus package has already changed the underlying EU framework, while Germany still needs to complete its national legislation.
Keeping those two tracks separate helps teams distinguish confirmed EU requirements from details that could still change through the German implementation process.
3. Review the CSRD work you’ve already completed
Falling outside the revised mandatory scope doesn’t automatically make previous sustainability work redundant.
Data collection, governance controls, supplier information and materiality assessments may still support customer requests, investor reporting or other regulatory requirements.
The aim isn’t to continue a full CSRD program unnecessarily. It’s to identify which parts of the work still create value.
4. Strengthen the reporting foundations if you remain in scope
Companies that remain within scope can continue building the foundations needed for reliable reporting, including:
- Clear data ownership and responsibilities
- Documented methodologies and assumptions
- Supporting evidence and internal controls
- Double materiality assessment
- Processes that support review and assurance
These foundations are harder to build at the last minute than the final disclosure itself.
5. Prepare for the revised ESRS
Compared to ESRS (2023), ESRS (2026) has a 61% reduction in the number of mandatory data points, as well as simplifying the materiality assessment and enhancing the interoperability with international standards and other EU legislation.
For businesses, reporting processes need to be made flexible enough to accommodate the revised requirements – and any future amendments – rather than being locked into the original 2023 data point structure.
Prepare for CSRD in Germany with Sweep
CSRD requirements have changed, but the need for consistent, traceable sustainability data hasn’t.
Sweep is a sustainability intelligence platform that helps organizations build a reporting foundation that adapts as regulations evolve, so teams don’t have to rebuild their data every time the scope, standards or disclosure requirements change.
With Sweep, companies can:
- Centralize sustainability data from across the organization and the value chain in a single governed environment.
- Support double materiality and ESRS reporting using the same underlying data and evidence.
- Maintain traceability so figures, methodologies, assumptions and supporting documents can be reviewed when needed.
- Reuse governed data across reporting requirements, helping teams avoid duplicating the same collection and validation work.
- Use Sweepy AI to support data mapping, validation and disclosure preparation, while keeping people in control of final decisions.
- Adapt reporting workflows as requirements change, without having to start again from fragmented spreadsheets and separate systems.
This flexibility is particularly useful in Germany, where companies need to prepare for an EU framework that has already changed while national implementation is still underway.
When reporting rules change, companies shouldn’t have to rebuild their sustainability data from scratch.
Explore Sweep’s sustainability reporting platform to see how your team can prepare for CSRD and other reporting requirements from one connected data foundation.
