FAQ on the CSRD report

The early access version of the new DNK platform enables companies to create their sustainability reports digitally and be guided step by step through the reporting process. This version is already functional and contains extended features compared to the beta version (all details can be found in the changelog PDF). 

As we are continuously optimising the platform, particularly with regard to possible changes to the CSRD as a result of the EU Omnibus Package, it is undergoing ongoing development. Users of the early access version will therefore benefit from the latest features and improvements at an early stage.

(As of 14 March 2025)

An overview of current features, fixed bugs, features in development, and planned future features can be viewed here or within the platform by clicking on the Early Access Version emblem.

(As of 14 March 2025)

The new DNK platform will initially focus on reporting in German. The option to report in other languages may become available in the future.  

(As of 12 March 2024)

No, publication is voluntary.

(As of 15 November 2024)

The Omnibus Package on Sustainability Reporting is an initiative by the European Commission to simplify and harmonise existing regulations in the area of sustainability reporting and corporate responsibility. The package includes amendments to several directives and regulations, including the CSRD and the CSDDD. Key measures include reducing reporting requirements for smaller companies, postponing deadlines and simplifying standards.

On 26 February 2025, the European Commission presented a draft of the package, which has not yet been finally adopted. Changes are still possible, meaning that smaller companies could end up being subject to reporting requirements after all. It would therefore be unwise to stop preparations at this early stage. Even if fewer companies are formally required to report in future, we expect that more and more SMEs will report voluntarily. Investors, customers and business partners increasingly expect transparency on sustainability issues. With our new VSME module, which we are currently developing, we are providing targeted support to companies that report voluntarily in applying the VSME reporting standard.

Regardless of possible regulatory changes, the DNK remains a reliable partner for sustainability reporting – both for companies that are required to report and those that report voluntarily.

(As of 12 March 2025)

Our offering has a modular structure: the first module is aimed at companies subject to reporting requirements. A second module for companies that report voluntarily is currently under development. The VSME module will be available from September 2025. Our goal is to tailor the VSME module optimally to the needs of users.

For the transition, we offer companies a gap analysis to help identify the differences between the previous DNK reporting standard and the VSME. In addition, a fillable VSME input form is available on the DNK platform, which contains the relevant VSME data points.  

(As of 23 July 2025)

How are the results from the double materiality analysis integrated into the DNK platform in order to create a report?

The new DNK platform enables you to create customised reports based on your materiality analysis. At the beginning of the reporting process, you can enter the results of your materiality analysis into the DNK platform. An input mask is available for this purpose, in which you can mark the reporting content that is material to your company at the level of ESRS topics, sub-topics and sub-sub-topics. The data points to be reported are automatically assigned based on this selection. If you are at the beginning of your materiality analysis, you will also be able to download an Excel template in the future. This will allow you to mark content to be reported during the materiality analysis. Once the materiality analysis has been finalised, the template can be uploaded to the DNK platform so that a customised report structure can be generated.

Does the DNK provide templates or tools, for example for involving stakeholders and creating a materiality analysis?

We have already published a quick guide on materiality analysis: In mid-February 2025, we will also publish a process guide that describes various steps for implementing materiality analysis, including practical tips, and discusses in detail different options for stakeholder engagement.

Can IROs be identified and analysed on the DNK platform?

No, the platform focuses on reporting. IROs in the context of double materiality analysis must be identified in an upstream process.

What are IROs?

IRO stands for ‘Impacts, Risks, and Opportunities’. IROs must be identified and assessed as part of the double materiality analysis.

Impacts are identified as part of ‘impact materiality’ (inside-out). They refer to the effects that the company has on people and the environment through its business activities, relationships or products. These effects can be positive or negative, as well as actual or potential. They indicate the company's negative or positive contribution to sustainable development.
Risks and opportunities are identified as part of ‘financial materiality’ (outside-in). They refer to the negative or positive financial effects of sustainability aspects (ESRS range of topics) on the company. They can have a short-, medium- or long-term impact on the company's development, financial position, financial performance, cash flow, access to finance or cost of capital.

Further information on the description, identification and formulation of IROs can be found here.

How long will the DWA take to implement and how many staff will be required? 

The duration of a DWA implementation can vary depending on the size of the company, the complexity of its business activities and the resources available. Regardless of these factors, it requires a considerable investment of time and personnel, which must be carefully planned. A clearly designated responsible person or an interdisciplinary core team, ideally consisting of senior managers and experts from relevant departments, should centrally manage and coordinate the process. This responsible person or team is responsible for planning, implementing and documenting the analysis, drawing on expertise from departments such as sustainability, purchasing or logistics as needed. A clear schedule, agreed upon with all parties involved at an early stage, ensures that all necessary resources and capacities are planned for. The involvement of senior management is also very important to ensure that the team has all the necessary resources at its disposal and that the process runs smoothly.

Does the DWA have to be carried out before the reporting year?

The DWA does not have to be carried out before the reporting year. However, it is recommended to start early, as it is relevant for the further steps of sustainability reporting.

Who should carry out the assessment of material topics? 

The assessment of material topics should be carried out with the involvement of key internal and external stakeholders. It should be noted that only stakeholders who have a very good understanding of sustainability issues relating to the company's industry should be involved. It must be ensured that the selected stakeholders are able to correctly identify and assess the impacts, risks and opportunities. Internal stakeholders can be employees, managers or employee representatives, while external stakeholders include sustainability experts, suppliers, business partners, consumers, local groups, authorities, legislators and civil society organisations. ‘Silent stakeholders’, such as nature or future generations, should also be taken into account.

Is stakeholder engagement mandatory?  

The CSRD stipulates that stakeholders should be engaged. Companies must explain how they involve stakeholders in their sustainability reporting process to ensure that reporting is relevant and comprehensive (see ESRS 2 SBM-2 and IRO-1). The directive distinguishes between two stakeholder groups: affected stakeholders and users of the sustainability report.

Affected stakeholders are those who are directly or indirectly, positively or negatively, actually or potentially affected by the company's activities.

Users of the sustainability report are stakeholders who have an interest in the company's sustainability-related information and who can potentially influence the company positively or negatively.

Which parts of the DWA can be handled internally, and in which areas is the involvement of external stakeholders necessary?

Which areas of the double materiality analysis can be handled internally depends entirely on whether the company has the necessary knowledge and resources internally to meet the requirements.

The double materiality analysis is reviewed by external auditors, who ensure that all methodological requirements have been met and that the impacts, risks and opportunities have been correctly and truthfully identified and assessed. Some companies are able to handle all requirements internally. Other companies rely on the support of external stakeholders to implement the methodological requirements or to correctly identify and assess the impacts, risks and opportunities.

As a rule, the methodological requirements can be met internally if a responsible person thoroughly familiarises themselves with the EFRAG reporting standards and guidelines.

With regard to the identification and assessment of impacts, risks and opportunities, ESRS 1 requires that these reflect the entire value chain of the company. IROs relating to a company's own business activities can usually be assessed effectively by internal stakeholders if they are able to correctly identify and evaluate the impacts, risks and opportunities. If they are unable to do so, it is advisable to consult sustainability experts who can correctly assess the impacts, risks and opportunities on the basis of scientific findings.

IROs relating to the upstream or downstream value chain can in some cases be assessed more specifically by external stakeholders such as customers or suppliers.

In addition, many risks and opportunities affect the attractiveness of the company or product for customers and investors. For many issues of financial materiality, it is therefore advisable to involve external stakeholders.

At what point should external stakeholders be involved? Is it necessary to consult external stakeholders in the first reporting year, or can the process be started internally and gradually expanded to include external stakeholders over the years?

Companies can take a step-by-step approach in the first reporting year by first starting internally with the DWA and gradually expanding the involvement of external stakeholders over the years. This is particularly useful for small and medium-sized enterprises (SMEs) with limited resources. A stakeholder analysis can help to narrow down the group of affected parties in advance in order to reduce the time and effort required. Such an approach enables companies to first establish a solid internal foundation before integrating the perspectives of external stakeholders into the process.

Does the assessment of IROs within the framework of the DWA have to be substantiated by scientific facts, or is an internal assessment sufficient?

The CSRD does not explicitly stipulate that the results of the double materiality analysis must be substantiated by scientific data. However, as the results should be representative and accurate, it is recommended that companies use scientifically validated data and information, particularly when identifying and assessing relevant environmental IROs (including ESRS E1-5). Suitable sources that companies should analyse as part of their desktop research vary greatly depending on the sustainability topic and the company's own industry. However, there are some freely accessible databases, tools and sector materiality profiles with verified information on typical social and environmental impacts and risks of various industries/products/services, e.g.:

• CSR Risiko-Check  
• SASB Materiality Finder
• ENCORE - Exploring Natural Capital Opportunities, Risks and Exposure
• WWF Risk Filter Suite
• IBAT - Integrated Biodiversity Assessment Tool
• Global Slavery Index 

Are there specific requirements for documenting stakeholder management/engagement in the CSRD report?

ESRS 1, para. 24 stipulates that the involvement of key affected stakeholders is a central component of a materiality analysis. Key stakeholders must be involved in the procedures for identifying and assessing actual and potential negative sustainability aspects, which are then incorporated into the assessment process to determine material impacts. According to ESRS 2, SBM-2, a description must be provided of how stakeholder engagement took place in the corporate strategy. However, no specific requirements are made regarding the frequency, form and scope of stakeholder engagement. A detailed explanation is advisable, however, especially in view of the audit.

Are there specific requirements for stakeholder mapping under the CSRD?

There are no fixed requirements for stakeholder mapping, but it is recommended to use a systematic and transparent method for identifying and prioritising stakeholders. This can be done, for example, using a matrix or other visual representations.

How specifically must the assessment criteria be defined internally in order to determine whether an issue is material? Is there a ready-made scheme that can be used for this purpose?

There are no uniform, ready-made schemes that apply to all companies. Rather, companies must develop a tailor-made assessment system that is tailored to their specific circumstances, industry requirements and strategic objectives.

The following guiding questions may be helpful for the assessment:

• Severity/degree of severity is determined by the extent, scope and irreversibility (remediability) (ESRS 1 para. 45):
• Extent: How serious is the (potential) negative impact? Is the extent, for example, minor/moderate/significant/high? The scale is determined individually by the company.
• Scope: How great is the degree of impact? (e.g. how many people are affected?)
• Irreversibility (remediability): How difficult would it be to prevent or remedy the (potential) negative impact? Are the negative impacts easy/moderate/difficult/impossible to remedy? The scale is determined individually by the company.
• Probability: How likely is it that this impact will occur?

At what level of aggregation must the DWA be carried out? At the process level, site level or only at the level of the IROs that affect the entire company?

The DWA must be carried out for the entire consolidation scope of the company or group of companies. The aggregation level is therefore specific to each company. The scope of consolidation of the financial management report can be used as a starting point (ESRS 1 para. 62). It is important that the entire value chain is considered and included in the DWA.

Further information on the scope of consideration can be found here and in our process guide (available from mid-February 2025) on DMA.

When identifying and assessing IROs, there are cases where it is not clear whether the impacts are positive or negative. How should this be handled?

The wording of the impacts should clearly indicate whether they are positive or negative. This is important because the subsequent assessment differs depending on the type of impact. When assessing positive impacts, only the extent and scope of the impact should be taken into account. In the case of negative impacts, however, the extent and scope as well as the remediability must be assessed. If it is not clear whether an impact is positive or negative, it is recommended to separate this impact and formulate two impacts. One impact is clearly positive and the other negative. The assessment is then carried out for both impacts.

When assessing the materiality of impact over time for the three phases – short term, medium term and long term – do IROs have to be assessed separately, or can this assessment also be summarised?

The CSRD does not provide any specific guidelines on this. To obtain a concrete and representative result, it is recommended that each impact or combined impacts be assessed separately for the three time dimensions – short-term, medium-term and long-term. This differentiated assessment makes it possible to accurately identify the specific impacts, risks and opportunities in the different time periods and to develop targeted strategies. The time categorisation is not specified by EFRAG, so companies can classify this individually.

Example: Energy-saving measures can lead to direct cost savings in the short term, while the switch to renewable energies ensures a more sustainable energy supply in the medium term.

How extensive and detailed should the value chain be considered?

In principle, the materiality analysis covers a company's entire value chain (EFRAG Guidance IG1 para. 2; ESRS 1 paras. 63-66). In practice, this means that the first step of the materiality analysis – describing the value chain and conducting a broad analysis of potential material sustainability topics and IROs – should cover the value chain as comprehensively as possible. This is the only way to ensure that highly relevant sustainability topics are not excluded from the scope of the materiality analysis. Particularly in the case of manufacturing companies that purchase various intermediate products and raw materials internationally, significant risks of environmental damage and human rights violations (inside-out perspective) often arise at the lower levels of the supply chain. However, when identifying potential material IROs, the focus can be placed on those stages, geographical areas, areas of activity/sectors, suppliers, customers, etc. in the value chain where they are likely to occur (EFRAG Guidance IG2 para. 3). Companies do not have to disclose information about every single player in the value chain in their sustainability reports. Rather, the aim is to report essential information about the upstream and downstream value chain. Different sustainability aspects may be relevant for different parts of the value chain. The information disclosed therefore only needs to cover those parts of the value chain that are material to the respective sustainability aspect (ESRS 1 para. 64).

When assessing impact materiality for the three stages of the value chain (upstream, downstream, own business area), do IROs have to be assessed separately? Or can this also be done collectively?

The CSRD does not provide any specific guidelines on this. It is only necessary to indicate where the impact occurs in the value chain. It is therefore advisable to assess each impact separately for the three stages of the value chain – upstream, downstream and own business area. Within this framework, it is also possible to indicate if part of the value chain is not relevant to the company. This differentiated assessment makes it possible to accurately identify the specific impacts, risks and opportunities in the various areas of the value chain and to develop targeted strategies.

How are topics excluded in the DWA process, and how is the transition from a comprehensive longlist to a focused shortlist comprehensibly justified and classified?

All topics/sustainability aspects mentioned in the list of sustainability topics from ESRS 1 AR 16 should at least be considered in the materiality analysis, i.e. companies should check for each topic mentioned whether it is applicable to their own company (for example, by means of an environmental analysis or in consultation with stakeholders). The topics identified in this process are then compiled in a long list of topics. Topics that prove to be inapplicable are removed from the long list. Such deletion of topics should be well justified for later review and documented together with the reasons. The result of this process is the development of a company-specific shortlist that only includes topics that are applicable to the company. The shortlist forms the basis for the next phase of the materiality analysis, in which the applicable topics are comprehensively assessed in terms of their impact, risks and opportunities.

Example: A software development company has determined that it has no direct or indirect impact on water resources due to its business model, which focuses on digital services, and its value chain, which does not involve any physical production processes. As its main activities take place in urban offices that are subject to standard wastewater regulations and its supply chain consists mainly of digital services, there are no risks of water pollution. These findings led to the decision to remove the issue of water pollution from the long list.

How is the threshold for determining the materiality of issues determined and set? Is the threshold set in advance or can it be defined after the IROs have been assessed?

The CSRD requires companies to set ‘appropriate’ thresholds, but does not specify specific values. The selection of these thresholds depends heavily on the chosen assessment methodology and should be well justified and documented to ensure transparency. 

Example: A company uses a scoring system in which issues are rated on a scale of 1 to 4 and sets a threshold of 2.5 as the average value to determine materiality. 

It is not mandatory to set the threshold before assessing the IROs. For more information on a possible approach, please refer to our process guide (available from mid-February 2025) on the DMA.

The Sustainability Campus offers a wide range of support services from the DNK. It accompanies you on your way to completing your sustainability report and provides you with a free initial consultation by telephone and email. For further, individual advice, you can draw on the network of DNK guides. In addition, a comprehensive, practical range of information and training on sustainability reporting in accordance with CSRD is available – from webinars and explanatory videos to helpful documents such as guidelines and fact sheets.

Find out more here: DNK Sustainability Campus

That depends entirely on how deeply sustainability is already anchored in the company and to what extent the necessary data and facts are already available in processed form.

Our 2018 user survey showed that the time required to prepare the DNK declaration varies greatly, averaging around 21 days. However, even a significant time investment is worthwhile if the process helps the company clarify its sustainability strategy, the goals it wants to set and the measures it will take to achieve them.

The application of the DNK is free of charge. The internal costs for the company depend on the time required to obtain the data.

The review of a DNK declaration by the DNK office relates exclusively to the formal requirements of the DNK and serves primarily to provide procedural support to the report authors. The DNK office accepts no liability for the quality, completeness, timeliness and accuracy of the information contained in the DNK declarations or for compliance with the legal requirements of the reporting obligation under the CSR Directive Implementation Act (CSR-RUG) and the EU Taxonomy Regulation. Responsibility for the accuracy and quality of non-financial declarations and reports and for compliance with the legal requirements under the CSR-RUG and within the meaning of the EU Taxonomy Regulation lies solely with the companies.

The RNE therefore does not issue a certificate.

If companies wish to increase the credibility of their DNK declaration, the German Council for Sustainable Development (RNE) recommends having the content of individual or all information in the DNK declaration reviewed by an external auditor. This audit should be based on common standards (such as the International Standard on Assurance Engagements (ISAE) 3000 Revised or the Eco-Management and Audit Scheme (EMAS)). A content review of individual or all information in the DNK declaration can be carried out by auditors, EMAS environmental verifiers or other suitable audit service providers. If a content review is carried out by auditing firms, it can be carried out with reasonable assurance or limited assurance for the audit opinion. However, the RNE recommends that statements in the DNK declaration be audited with reasonable assurance, as is the case with the management report.

The presentation of information in sustainability reports does not appear to be suitable for potential users in the capital market, as it lacks comparability and quantification in particular. For this reason, the German Council for Sustainable Development, together with representatives of the capital market, has selected a set of performance indicators from common reporting standards and described criteria. This provides a concise and clear overview of the key information on a company's sustainability performance. In addition, it can be assumed that much of the information required for the DNK declaration is already available if your company has already published a sustainability report.

Companies share responsibility for sustainable development. They should document how they fulfil this responsibility to the public. The capital market in particular is increasingly using this information to assess the opportunities and risks of capital investments and lending more comprehensively.

But reporting also has a strong impact on the company itself: reporting is not just about collecting data, but also about taking a close look and analysing. This reveals weaknesses, but also untapped opportunities. The company can see whether it is complying with all laws and regulations (compliance).

Another important effect is that the workforce becomes more aware of and motivated to act sustainably. In addition, companies show how they are working together with politicians and society to achieve overall sustainable development. This task requires the involvement of all partners. German sustainability policy and the national sustainability strategy potentially provide a sounding board for corporate contributions to sustainability.

By reducing the focus to the essential aspects, the DNK supports the clear and comparable presentation of a company's sustainability performance.

The German government wants to use the National Action Plan on Business and Human Rights (NAP) to enforce compliance with human rights in global supply and value chains. The German Sustainability Code (DNK) offers the opportunity to comply with the fourth core element of the NAP – reporting – by submitting a DNK declaration.

Companies that want to disclose their commitment to protecting human rights in detail can select in the database that they want to use the DNK including the NAP reporting points. The supplement is then displayed and reviewed for formal completeness by the German Sustainability Code Office as part of its critical review process. Responsibility for the content remains with the reporting organisations.

The NAP Helpdesk of the Agency for Economic & Development provides free advice on the requirements of the National Action Plan, NAP monitoring and international projects in the field of sustainability in general. You can find FAQs about the National Action Plan on the NAP Helpdesk website.

The CSR Directive Implementation Act (CSR-RUG) requires certain companies to provide non-financial reporting in accordance with specific guidelines. The DNK can be used to prepare a non-financial report in accordance with the CSR-RUG. This requires some additional information, which is indicated when preparing the DNK declaration.

It is possible to supplement the DNK declaration retrospectively. However, we only recommend doing so if it is urgently necessary, e.g. in the case of important key figures that were not yet available when the DNK declaration was submitted.

Numbers are important, but sustainable business practices depend above all on ethical conduct and a vision for the future. Among other things, the benefit lies in taking individual people seriously in their actions and not hiding one's own responsibility behind mountains of data.

The German Sustainability Code helps to maintain credibility and access to markets, but also to continuously develop innovation and new thinking in companies while incorporating proven principles. With your declaration to the DNK, you demonstrate that you can report beyond your immediate company boundaries, including your supply chains. As a supplier, you can use the DNK to showcase your sustainability performance and thus score points when establishing new supply relationships.

You can also use the DNK to evaluate the economic performance of your company more comprehensively, which you would traditionally demonstrate with an annual report and numerous financial indicators. Show that your company is positioned for the long term to realise opportunities and is aware of the risks associated with sustainability issues. Consumers, politicians and financial service providers are asking for this. The DNK helps to provide answers to these stakeholders.

The primary target groups that use the DNK declarations are:

• the company's own management, to steer sustainability within the company and to analyse and manage opportunities and risks;
• the company's own and future employees who want to work for a company that demonstrates comprehensive responsibility;
• customers and suppliers who value sustainability in the value chain;
• political decision-makers who want to gain an impression of sustainable business practices;
• and financial market players, to enable them to better assess the opportunities and risks of capital investments and loans.

Large companies can use the DNK to provide their partners in the supply chain with a simple tool that meets the sustainability requirements of their customers.

Non-governmental organisations and academia are also likely to be potential users. As the economy makes greater use of the DNK and the number of DNK declarations increases, the interest of the target groups will also grow.