29. September 2023

DRSC publishes Results of its Survey on the Implementation of ESRS in the German DAX 40 Companies 

In summer 2023, the DRSC conducted a short survey among the DAX 40 companies on the implementation of the European Sustainability Reporting Standards (ESRS). 39 of the DAX 40 companies participated in the survey. The results of this online survey are available here.

The ESRS are mandatory for DAX 40 companies for financial years starting 1 January 2024. In the short survey, the companies provided information on whom the responsibility for the ESRS implementation project was assigned to, the start date and the current status of the project as well as the greatest difficulties that the companies currently see in the ESRS implementation. Furthermore, the companies indicated which other sustainability reporting standards they are considering/using.

A few months before the mandatory first application of ESRS, this survey provides information on the approach and challenges of ESRS implementation in the DAX 40 companies. For about 80% of the companies surveyed, these include unclear reporting requirements and the quality/verifiability of the data.  The survey also shows that these companies are considering/using various other reporting standards. For more than 70% of the companies, these include GRI, which is currently chosen as the basis for separate sustainability reports to meet the NFDR requirements that apply up to and including 2023. In addition to ESRS, more than half of the companies also consider the IFRS sustainability standards (IFRS S1 and S2, 22 companies) or consider/use the industry-specific SASB standards (23 companies), which are both not mandatory.

The companies see one of the greatest difficulties in the lack of clarity regarding the ESRS reporting requirements. According to the information provided, this is partly due to the pending legal process (with ESRS yet to be finalised at the time of the survey). The ESRS were published with the adoption of the Delegated Act by the European Commission on 31 July 2023. On the other hand, the companies are dealing with questions regarding the understanding of the ESRS and the content of the sustainability reports. The DRSC conducts “user forums” for questions on the implementation of ESRS. Thereby, the DRSC creates a format in which company representatives of German companies can exchange views on questions arising from the initial application of the ESRS.

Georg Lanfermann, President des DRSC, comments on the results „DAX 40 companies are in the middle of implementing the European Sustainability Reporting Standards. International consistency remains an important objective. The large number of German companies that are also required to prepare sustainability reports will benefit from the implementation experiences of these companies.”