Where is the CSRD report positioned?
The CSRD report is a mandatory part of the management report.
This means (ESRS 1 Section 8, para. 110):
Sustainability information is not disclosed separately, but within the management report
The content is presented in a dedicated section called the “Sustainability Statement”
This firmly integrates sustainability reporting into corporate reporting and gives it a corresponding level of importance.
How do you structure the sustainability statement within the management report?
Observe the following requirements (ESRS 1 Section 8.1, para. 111):
Clearly separate ESRS disclosures from other content in the management report through a dedicated chapter (e.g. “Sustainability Statement”)
Structure the content so that it is easy to find and understand
Ensure that the report is both human-readable and machine-readable
How, where, and when do you submit the report?
You submit the report as a single combined document to the Company Register.
The following applies:
There is no separate submission for CSRD and the financial report
The auditor’s assurance report must be included in the document where reporting is mandatory
In the future, the entire management report including the sustainability statement must be published in ESEF format (XHTML + XBRL tags). The XBRL taxonomy for ESRS reporting is still under development and is expected no earlier than 2027
Disclosure deadlines for German companies:
Capital market-oriented companies: within 4 months after the balance sheet date
Non-capital market-oriented companies: within 12 months after the balance sheet date
Submission must be made together with the annual financial statements, the management report, and the audit opinion including the conclusion on non-financial reporting
Capital market-oriented companies must publish the sustainability statement as part of the management report on their website. For consolidated reports, the management report may need to be available in multiple languages depending on the locations and local legal requirements of subsidiaries. English is usually accepted
How is the audit by the statutory auditor carried out?
You provide the complete management report including the sustainability statement. The audit of the sustainability statement under ESRS is currently performed with limited assurance.
What does the auditor focus on and what is reviewed?
The auditor ensures that disclosures are verifiable, consistent, and fully traceable. This involves tracing reported figures back to their data sources.
Key focus areas include:
Data quality: Are the figures accurate and complete?
Changes: Can deviations compared to the previous year be explained?
Evidence: Is there reliable supporting documentation for each metric?
In practice, this means:
Auditors reconcile reported values with underlying data
They verify that all supporting documentation is complete
They independently recalculate key metrics
This ensures that every figure in the report can be clearly substantiated.
For internal documentation purposes, auditors will typically want to retain reported data and supporting evidence from Tanso.
How do you report to other stakeholders?
A CSRD report is highly formal and detailed. For stakeholders, you can additionally:
Create summaries
Highlight key content
Present information in a more accessible format (e.g. presentations or short reports)
The CSRD report remains the authoritative reference.