CO2 reporting requirement (CSRD) in Germany 2023

Climate change is a very important topic for everyone. This means we have to work harder and find better measures to save CO2.

The next step towards a sustainable and low CO2 environment is the CO2 reporting obligation for companies, which will apply from 2024.

For companies, this means that documentation of their own sustainability efforts will begin at the start of 2023.

Also in the area of mobility: The CO2 reporting obligation paves the way for sustainable company mobility.


What is the CO2 reporting requirement (CSRD)?

The CO2 reporting obligation refers to the new EU Corporate Sustainability Reporting Directive (CSRD). It replaces the previously applicable Non-Financial Reporting Directive (NFRD) from 2014.

The directive regulates the sustainability reporting of European companies. As a result, not only the potential impact that climate change is expected to have on the company must now be documented (outside-in perspective).

Rather, the actual effects that the company's business activities have on the environment and climate must also be disclosed (inside-out perspective). The aim of the new directive is to increase transparency in the area of sustainability.

The topic of sustainability thus becomes more of a focus for companies and is promoted with a view to the future.

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To which companies does the new CSRD apply?

The comprehensive update of the CO2 reporting obligation also expands the group of companies that are required to prepare a sustainability report.

Under the previous regulation, only around 500 companies in Germany were required to submit a sustainability report.

According to current estimates, around 15,000 companies will be subject to the new Corporate Sustainability Reporting Directive in the future.

Up to now, sustainability reporting has applied to capital market-oriented companies with more than 500 employees, financial service providers, cooperatives, credit institutions and insurance companies.

The new CSRD now already requires smaller capital market-oriented companies with 10 or more employees to submit a sustainability report if they have a balance sheet total of at least 350,000 euros or sales of at least 700,000 euros.

In addition, there are companies with an annual average of more than 250 employees that also have either a balance sheet total of more than 20 million euros or net revenues of more than 40 million euros.

My company falls under the new CSRD. What data does my company now need to collect regarding sustainability?

Sustainability reporting is multi-layered and covers several areas. The new CSRD is based on the established ESG framework, which takes into account environmental, social and governance aspects.

The focus of future sustainability reporting will be CO2 reporting. However, according to the CSRD, the following contents must also be documented in addition to CO2 balancing in relation to sustainability:

  • Business model and strategy in terms of resilience, opportunities and risks, stakeholder plans and interests, and how the strategy has been implemented in the past.
  • Legislated goals and progress toward achieving the above.
  • Climate management and the roles of administration and management.
  • Corporate policies with regard to sustainability issues.
  • Measures taken and their results.
  • Actual and potential adverse effects for the company.
  • Risks relating to sustainability issues and the associated dependencies of the company.

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How a mobility budget helps you with the CO2 reporting obligation

Particularly in the area of employee mobility, many companies still lack usable data that will have to be available for reporting in the future. If the company does not have its own data, statistical values are currently assumed. However, these values can assume a high proportion of gasoline-powered private vehicles. For your company, however, this has a negative impact on the CO2 tax price, which is thus set higher.

It therefore makes sense for your company to record the mobility data in full.

The solution for mobility data collection: A mobility budget for employees

If your company introduces a mobility budget for its employees, your company's mobility is clearly collected in one place. Employees can cover their mobility expenses with a mobility budget card or receive reimbursement if they have paid in advance. This gives your company an insight into the mobility behavior of its employees and can then evaluate the data anonymously and incorporate it into CO2 reporting.

What happens if the mobility budget does not cover all of the employees' mobility or if the employees do not submit all of their mobility expenses? For example, because their monthly mobility budget has already been used up or they prefer to pay for their mobility expenses themselves. In order to be able to record this data as well, it makes sense to complete the data basis by means of anonymized surveys among the workforce.

The mobility mix in your company is thus recorded and documented. If the mobility mix is not sustainable, measures can be taken to improve the CO2 balance of the company's mobility.

The mobility budget has another advantage: All CO2 emissions caused with the mobility budget can be automatically compensated directly via climate projects.

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