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Implementation of ESG standards at DAX companies

The adoption of the Corporate Sustainability Reporting Directive (CSRD) and its specification in the European Sustainability Reporting Standards (ESRS) constituted the achievement of another milestone for sustainable finance. The fundamental objective here is to transform the EU into a modern, resource-efficient and competitive economy with no net emissions of greenhouse gases by 2050. To achieve these changes, besides the large public interest entities, large corporations, certain banks and insurance companies as well as small and medium-sized enterprises with a stock market listing will also have to prepare comprehensive sustainability reports as part of their management reports.

Scope of application of the ESRS 

The ESRS have to be implemented by companies that fall within the scope of the CSRD. This includes an estimated total number of around 15,000 German companies that will successively have to prepare sustainability reports in accordance with the Accounting Directive and the ESRS. The DAX 40 companies will have to incorporate a sustainability report in accordance with the ESRS into their management reports already for the 2024 financial year.

Survey by the Accounting Standards Committee of Germany (ASCG)

To show how the DAX 40 companies are dealing with this challenge and to highlight the difficulties that are currently being encountered in the implementation of the ESRS, in the summer of 2023, the ASCG conducted an online survey of the companies that make up the DAX40 Index. The aim was to gain insights about the status and the difficulties of the ESRS implementation project. The following five questions were asked in this survey, whereby multiple answers were possible: 
(1) Where is the Project Management Office located for your ESRS implementation project?  
(2) When did you start your ESRS implementation project? 
(3) How far along is your implementation project? 
(4) Which implementation aspects are currently causing the greatest difficulties? 
(5) Are you currently considering other sustainability reporting standards or using them in addition for the ESRS implementation? If yes, which ones? 
In the following section we present the survey results. 

Please note: In the final conclusion we point out the significance for non-DAX companies, too. 


At most companies, the Project Management Office for the ESRS implementation project is currently situated at board level. Almost half of the companies surveyed stated that the project responsibility currently lies with the CFO or CEO or the finance department at the company. Setting up appropriate staff units should moreover help with the organisation of the new challenges that have to be addressed. 

Implementation status  

Out of 40 companies, 37 have started implementing the ESRS. 70% of the DAX 40 companies have already established reporting processes. Around 23 of these companies have addressed selected sustainability reporting topics (environmental, social or governance), while five companies have already implemented reporting processes for all these reporting topics. 20 companies can already point to a completed materiality assessment (cf. Fig.1).

Challenges for the implementation 

All companies surveyed have major difficulties in implementing the ESRS. The biggest challenges are seen in the “lack of clarity regarding the ESRS requirements” and the “quality and verifiability of the data”, both of which are mentioned by about 80% of the companies (cf. Fig.2). In addition, for 74% of the companies, “data availability” constitutes a major problem and, for 70% of the companies, it is limited “human resources” as well as limited “time resources”. Under “Other”, several companies point out that the, as yet, incomplete legislative process (i.e. the still pending publication of the final ESRS by the EU Commission) and, thus, the unclear legal situation are highly problematic. Furthermore, other companies also see these difficulties but mention them under the category “lack of clarity regarding ESRS requirements”. The same applies to the difficulty of “identifying specific requirements in relation to the materiality analysis”, which one company mentions under “Other”. 

Other comments from the companies 

The companies were moreover surveyed about other reporting standards that they are currently considering/using for the implementation of the ESRS. It is noticeable that there is a large number of multiple responses here that reflect the variety of reporting standards. Consequently, it is likely that an additional challenge will be to track the developments and thus the changes and differences in the reporting requirements and to reflect and explain these changes in the sustainability reporting. Furthermore, it is pointed out that for some topics (e.g. biodiversity) there are still no recognised or established assessment methods. It is therefore expected that implementing and auditing these standards will entail a great deal of effort and expense. 

Conclusion for non-DAX companies 

The survey of the DAX companies about the approach to the implementation of the standards and the challenges that have to be addressed shows what soon lies ahead for non-DAX companies, too. For this reason, action is required now already in the form of the systematic collection and preparation of information. 

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