Reporting obligations as of October 2026
Since 2025, the EU has changed its sustainability reporting rules twice: first it postponed deadlines, then it narrowed the group of companies that have to report. This overview only lists what official sources say.
| Topic | Status | Source |
|---|---|---|
| Who has to report (EU) | Amending Directive (EU) 2026/470 from the Omnibus package has been in force since 18 March 2026. It limits the obligation to companies with an average of more than 1,000 employees and net turnover of more than EUR 450 million. | Directive (EU) 2026/470, European Parliament |
| Transposition by member states | Member states have until 19 March 2027 to transpose the changes into national law. | European Parliament |
| Germany | The act transposing the CSRD has not been passed. The government bill has been before the Bundestag since September 2025; an amendment tabled by the coalition parties on 31 March 2026 is meant to align it with Directive (EU) 2026/470. Until the act enters into force, the German Commercial Code (HGB) still contains the rules on the non-financial statement. | Bundestag (DIP), BT-Drs. 21/7745, DRSC, Section 289b HGB |
| Standards (ESRS) | The European Commission adopted revised ESRS on 3 July 2026. Unless Parliament or Council object, they enter into force on 10 November 2026. They apply to financial years beginning on or after 1 January 2027; for financial years beginning in 2026, companies may already use them and must then state in their sustainability statement which version they apply. | European Commission, C(2026) 5010, EFRAG |
| Voluntary standard | On the same day, the Commission adopted a standard for companies with no more than 1,000 employees that report voluntarily. It replaces the 2025 VSME Recommendation and limits the sustainability information that reporting companies can request from such partners in their value chain for their own report. | C(2026) 5011 |
| German terminology | The German version of the ESRS was corrected on 9 August 2024. For the revised ESRS, the German and Austrian standard setters DRSC and AFRAC sent the Commission a reviewed list of German technical terms on 26 June 2026. | Corrigendum, DRSC |
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.
One German term, one English original
The ESRS were written in English; the German version in the Official Journal is a translation, and its terms are not always the ones you would expect. When a German sustainability report goes into English, the translation has to find its way back to the original: Konzepte become policies again, not concepts.
| German ESRS version | ESRS original | Literal, but not the ESRS term |
|---|---|---|
| Konzepte | policies | concepts |
| Maßnahmen | actions | measures |
| Kennzahlen | metrics | key figures |
| Angabepflichten | Disclosure Requirements | disclosure obligations |
| Interessenträger | stakeholders | interested parties |
| Sorgfaltspflicht | due diligence | duty of care |
| Arbeitskräfte des Unternehmens | own workforce | company employees |
| Nachhaltigkeitserklärung | sustainability statement | sustainability declaration |
The term pairs are taken from the DRSC and AFRAC list. What counts in the end is the version your company reports under. We record it in your terminology database, so nobody on the team translates from memory.
The name of the report is a case in point. The German version of the ESRS calls it Nachhaltigkeitserklärung (sustainability statement). The German government bill transposing the CSRD consistently calls the same part of the management report Nachhaltigkeitsbericht. Which name your company uses is something we settle at the start.
The German version is still changing
In August 2024, the European Commission corrected the German version of the ESRS, based on feedback from the German and Austrian ministries of justice. DRSC had already listed the shortcomings in September 2023. Since then, several core terms read differently (DRSC analysis):
| English | German until August 2024 | German since the correction |
|---|---|---|
| policies | Strategien | Konzepte |
| metrics | Parameter | Kennzahlen |
| workforce | Belegschaft | Arbeitskräfte |
That was not the end of it. DRSC and AFRAC kept reviewing the current version and, on 26 June 2026, sent the Commission a list of comments and suggested improvements as input for the German version of the revised ESRS. Three examples from the list:
Adjusting items. The reconciliation table in ESRS E1 renders them as Ausgleichsposten. DRSC and AFRAC consider this grossly misleading and suggest Überleitungsposten.
Accounting for GHG removals. According to the list, Verbuchung is not the right term here; the suggestion is Anrechnung.
Remediation. One English word, rendered in German sometimes as verbessern, sometimes as Abhilfe, Verbesserung or Sanierung. The list recommends making the translation consistent.
For translation, this means taking terms from the version a company reports under, not from memory. And keeping a record of which version that was.
One report, one language
Under the CSRD, sustainability disclosures sit in the management report. The same topics come up again in the earnings release, in the investor presentation and on the website. If the management report calls something a policy and the website calls it a strategy, an analyst reads two different things.
Sustainability and annual reports should be translated from the same terminology database, so that the same facts have the same names in both. This is how we work:
Same teams. We assign the same teams to each client, which keeps writing style and content consistent.
One terminology database. Client-specific and for all of a client’s texts: sustainability report, annual report and supporting documents.
Multi-stage editing. Every text goes through several checks, tables and figures included.
Financial background. Our English team has backgrounds in banking, consulting and accounting.
Secure file transfer. Besides encrypted email, we offer uploads and downloads with SSL encryption.
Beyond the disclosure requirements
Not every sustainability text is a required disclosure. Magazines, websites, presentations and employee communications have to persuade, and information alone won’t do that. We don’t translate those texts word for word, we adapt them, the way we adapt customer magazines and campaigns in our marketing work.
Under sustainability, our client list includes Audi, Bosch, Demag Cranes, HOCHTIEF and ProSiebenSat.1. You will find the full list in our Showcase.
Frequently asked questions
For companies in the Prime Standard of the Frankfurt Stock Exchange, Deutsche Börse requires reporting in German and English. Your legal department can tell you which documents that covers in your case. If you want to reach international investors, you need the report in English anyway.
Those of the German language version in the Official Journal of the EU. For the ESRS currently in force, that is the version as corrected on 9 August 2024. The revised ESRS will come with a new German version when the delegated act is published; DRSC and AFRAC submitted reviewed terms for it in June 2026.
Under Directive (EU) 2026/470, 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. In Germany, the transposition act has not yet been passed (as of October 2026); when the obligation starts for your company depends on that act.
To financial years beginning on or after 1 January 2027. For financial years beginning in 2026, companies may apply them voluntarily, and must then state in their sustainability statement which version they use.
The ESRS use sustainability statement. In German, both terms are in circulation: the German version of the ESRS says Nachhaltigkeitserklärung, the German government bill says Nachhaltigkeitsbericht for the same part of the management report. What matters is that your report sticks to one.
Yes, and it is the surest way to consistent terminology: the same client-specific terminology database and the same teams for both reports.
Figures and tables stay exactly as in the original in substance, while the notation follows English conventions: 1.234,5 becomes 1,234.5. Every text goes through several checks in our editing process, tables included.