Large companies must
comply with the CSRD obligations for the first time and prepare an NFS in
accordance with CSRD/ESRS. Since they are not yet subject to any sustainability
reporting obligations under the NFRD & CSR-RUG, in contrast to the
companies subject to reporting obligations in 2024, the companies have at most
been able to gain experience in the form of voluntary, partly non-standardized
disclosures on sustainability issues. This is shown by a non-representative
survey conducted during an ESG webinar: The companies that are required to
report for the first time are currently burdened with specific questions and
problems, such as system-technical adaptation of the IT infrastructure,
identification of supporting software, legal uncertainties, coupled with
discussions on the scope of the report. In addition, these companies report
numerous operational challenges, such as the hurdles of a first-time
preparation of the dual materiality analysis including comprehensible
documentation, stakeholder involvement, high administrative costs, interface
problems, setting up a sustainability structure, scarcity of resources, lack of
added value, unmanageable data management and finding the optimal start time
(Dr. Dienst & Partner GmbH & Co. KG, 2024). At the same time, the
German economy is complaining in the media about stagnation, increasing
bureaucracy and declining productivity (Löhr, 2025). This article provides a
“hands-on” guide, especially for small and medium-sized companies that will
have to deal with this topic for the first time in the foreseeable future.
