Where things stand in October 2026
The EU has changed its sustainability reporting rules twice since 2025. In short:
Who reports. Amending Directive (EU) 2026/470, in force since 18 March 2026, limits the obligation to companies with an average of more than 1,000 employees and net turnover of more than EUR 450 million. Member states have until 19 March 2027 to transpose it (European Parliament).
Germany. The act transposing the CSRD has not been passed (Bundestag). Until it enters into force, the German Commercial Code still contains the rules on the non-financial statement (Section 289b HGB).
Standards. The European Commission adopted revised ESRS on 3 July 2026 (C(2026) 5010). Unless Parliament or Council object, they enter into force on 10 November 2026 and apply to financial years beginning on or after 1 January 2027. Companies may use them for financial years beginning in 2026 and must then say which version they apply.
The full overview, with every source, is on our page Sustainability report translation. The deadlines for the 2027 reporting season are in our Reporting season 2027 checklist.
As of October 2026. This overview is not legal advice: we translate and edit, we do not advise on law. Your legal department and your auditor can tell you which obligations apply to your company.
Back to the English original
The German ESRS are a translation, and not always the one you would expect. Where a German statement says Konzepte, the ESRS original says policies, not concepts. Translate from the German alone and the English may read well, but it will not match the ESRS. Auditors and analysts who know the standards notice.
| German ESRS version | ESRS original | Watch out |
|---|---|---|
| Konzepte | policies | not concepts. Until the correction of August 2024, the German version said Strategien. |
| Maßnahmen | actions | not measures |
| Ziele, Zielvorgaben | targets | two German words for one ESRS term |
| Kennzahlen | metrics | not key figures. Before August 2024: Parameter. |
| Auswirkungen, Risiken und Chancen | impacts, risks and opportunities | a fixed phrase in the ESRS; keep it intact |
| Wesentlichkeit der Auswirkungen, finanzielle Wesentlichkeit | impact materiality, financial materiality | together they make up double materiality (doppelte Wesentlichkeit) |
| Nachhaltigkeitsaspekte | sustainability matters | not sustainability aspects; Nachhaltigkeitsthema is sustainability topic |
| Unternehmensführung | business conduct (ESRS G1) | not corporate governance here. Elsewhere it is: the Erklärung zur Unternehmensführung is the corporate governance statement (Section 289f HGB). One German word, two English terms. |
| Übergangsplan, Transitionsplan | transition plan | DRSC and AFRAC treat the two German words as synonyms |
| Wertschöpfungskette | value chain | Arbeitskräfte in der Wertschöpfungskette are value chain workers |
| Arbeitskräfte des Unternehmens | own workforce | not company employees. The 2024 correction replaced Belegschaft with Arbeitskräfte. |
| Interessenträger | stakeholders | not interested parties |
| Angabepflichten, Datenpunkte | Disclosure Requirements, datapoints | Disclosure Requirements with capitals, as in the ESRS |
| Umfang | scope | but greenhouse gas Scope 1, 2 and 3 stay Scope in German too (Scope-3-Kategorie) |
| Verwaltungs-, Leitungs- und Aufsichtsorgane | administrative, management and supervisory bodies | the ESRS umbrella term; in a German stock corporation, that means the Management Board and the Supervisory Board |
| Nachhaltigkeitserklärung | sustainability statement | not sustainability declaration |
Source: the DRSC and AFRAC list of key ESRS terms, submitted to the Commission in June 2026 (DRSC), and the DRSC analysis of the August 2024 correction. Both refer to the first set of ESRS. The revised ESRS will come with a new German version, so check the pairs against the version your company reports under.
The section itself has two German names. The German ESRS call it Nachhaltigkeitserklärung; the German government bill transposing the CSRD calls the same part of the management report Nachhaltigkeitsbericht. In English, the ESRS term is sustainability statement. Settle on one name per language at the start.
One termbase for the sustainability statement and the rest of the report
Under the CSRD, the sustainability statement is part of the management report. Its topics come back in the earnings release, the investor presentation and the company website. Every one of those places is a chance for the same thing to get two English names.
The surest way to one set of terms is a single termbase for the sustainability statement and the annual report, used by everyone who writes or translates either. Before the English version goes out, check that:
segment names, KPIs and program names are identical in the sustainability statement and the rest of the report
figures in the statement match the financial statements, down to the rounding
units and number formats follow English conventions: 1.234,5 becomes 1,234.5
cross-references point to the right sections of the English report
the names of boards and committees match the corporate governance statement
How the work is organized
Framework and version. Record what the report follows: the non-financial statement under the HGB, the ESRS as adopted in 2023 or the revised ESRS.
Name of the section. Decide what it is called in German and in English.
Termbase before text. Build it from the ESRS originals and last year’s report before the first chapter arrives, and decide who approves new terms.
Chapters in batches. Hand over sections as they are approved; the data-heavy parts are often the last to settle.
Figures after every update. Check tables and text against the German original each time the data changes.
Review. Plan time for the sustainability team to review the English, and ask your auditor early how they will deal with the English version.
For the annual report around the statement, see our German-English annual report translation guide.
Questions to ask a translation provider
Do they work from the English ESRS original, or only from the German version?
Which version of the ESRS do they use, and how do they record which one applies to your report?
Do they know the DRSC and AFRAC list, and the corrections made to the German version in 2024?
Can the same team work on the annual report, so that both share one termbase?
How do they handle tables, units and late data updates?
Who works on the narrative parts, such as strategy and the transition plan, where tone matters as much as terms?
How is unpublished data transferred and protected? An insider list under Article 18 MAR can include outside advisers with access to inside information.
Do they use machine translation or AI tools, and if so, where does your text go?
About BMP
Sustainability reporting is part of our IR/PR work, right next to annual reports. Under sustainability, our client list includes Audi, Bosch, Demag Cranes, HOCHTIEF and ProSiebenSat.1. You will find the full list in our Showcase, and how we work on these reports under Sustainability report translation.
Frequently asked questions
It is the section of the management report in which a company subject to the Corporate Sustainability Reporting Directive (CSRD) reports on sustainability matters under the ESRS. In German, it is called Nachhaltigkeitserklärung in the ESRS and Nachhaltigkeitsbericht in the German government bill.
Because the ESRS were written in English and the German version is a translation. Konzepte are policies in the original, Kennzahlen are metrics, Interessenträger are stakeholders. A literal translation produces terms that readers of the ESRS do not recognize.
Not in ESRS G1. There, Unternehmensführung is the German term for business conduct, according to the list of key terms published by DRSC and AFRAC. In the HGB, on the other hand, the Erklärung zur Unternehmensführung is the corporate governance statement. The translator has to know which of the two a sentence refers to.
Possibly, at least in German. The Commission adopted the revised ESRS on 3 July 2026, and their German version is published with the delegated act. DRSC and AFRAC submitted reviewed German terms for it in June 2026. Check your termbase against the version you report under once it is published.
With one termbase for both, built from the ESRS originals and last year’s report, and one person who approves new terms. Check segment names, KPIs, figures and cross-references across the sustainability statement and the rest of the report before publication.