CSRD Implementation: Insurers Welcome Pragmatic Approach
The GDV welcomes the draft bill for the implementation of the Corporate Sustainability Reporting Directive (CSRD) as an important step toward legal certainty in sustainability reporting.
Insurers in Germany, who are both users and creators of sustainability reports, support the goal of a one-to-one transposition of the European rules into national law. Particularly positive is the draft's inclusion of the unrestricted retention of the group clause for insurers. This is essential, as the separation of lines of business within insurance groups, such as separate areas for life, health, or property insurance, would otherwise lead to a "reporting overload" without any added value.
The planned exemption for companies with 501 to 1,000 employees for the financial years 2025 and 2026 is also explicitly welcomed, as it avoids unnecessary effort, considering the planned narrowing of the scope at the EU-level. Particularly welcome is also the fact that the draft bill incorporates the "stop-the-clock" provision: it postpones the initial application of the CSRD by two years, for large companies and for small and medium-sized listed companies, to the financial years 2027 and 2028, respectively.
Despite these positive elements, the GDV sees a need for further adjustments. A key issue is the pragmatic design of the auditor appointment process. Instead of requiring a separate appointment for the sustainability auditor, the GDV calls for an “opt-out solution”: in principle, the auditor of the annual financial statements should also be considered appointed for the sustainability report.
The GDV also urgently calls for the swift implementation of the coalition agreement’s promise to eliminate reporting obligations under the German Act on Corporate Due Diligence Obligations in Supply Chains as part of this legislative process, to provide legal clarity for affected companies.
Finally, the GDV criticizes that the compliance burden continues to be significantly underestimated. Industry-specific surveys show implementation costs up to 25 times higher than current estimates. A more realistic assessment of the burden would allow for a better evaluation of the proportionality of the regulation. Especially in this context, it is even more important that the German Government strongly advocates for simplifications at the European level, particularly regarding the ESRS sustainability standards.
The GDV will constructively support the legislative process following the cabinet decision, to shape a practical and efficient law.
