Preventing goldplating in the implementation of the CSRD

In its statement on the CSRD Implementation Act, Deutsches Aktieninstitut advocates the disclosure solution with regard to the electronic labelling of sustainability information. The presentation solution provided for in the government draft does not comply with the CSRD requirements, but is based on a translation error. It poses considerable legal risks for companies and unnecessarily increases the implementation effort.

In order to ensure practical implementation of the CSRD, avoid gold-plating and synchronise financial and sustainability reporting, the following changes are particularly necessary:

• Disclose sustainability reporting in the same way as financial reporting;
• Do not allow national electronic labelling requirements to begin before the ESEF Regulation comes into force;
• Inform employees about the sustainability report through the most appropriate level of company management;
• Exempt companies from the sustainability reporting requirement in the same way as for financial reporting.