Guest contribution by Stefan Weber and Alexander Fischer


  • About half of the companies place the mandatory disclosures on non-financial information within the Annual Report or Integrated Report
  • Large differences in the scope of non-financial declarations and non-financial reports
  • Only one company has not had the content of its non-financial statement audited by an auditor

Kirchhoff Consult AG, Warth & Klein Grant Thornton AG and the University of Applied Sciences Wedel have carried out the first study on the practical design of the CSR Directive Implementation Act (CSR-RLUG) for DAX 30 companies. All 27 of the DAX 30 companies whose financial year is the calendar year 2017 and who were thus obliged to publish a non-financial declaration (NFE) or non-financial report (NFB) for the first time after the CSR Directive by the end of April 2018 were considered.

Companies report in various forms
The study comes to the conclusion that the legal scope for localization is fully used. Just over half of the DAX 30 companies analysed place their NFE/their NFB within the Annual Report or Integrated Report. Four of these are placed by the NFE as separate chapters in the management report. Five other companies integrate their NFE into the management report and six locate their NRP outside the management report as a separate chapter. Twelve DAX 30 companies make use of the opportunity to publish their NFB outside the Annual Report or Integrated Report. Five of the companies published their NFB as a separate PDF. Another six place it in their sustainability report and one company states that its entire sustainability report is the NFB.

Extent of non-financial reporting varies widely
In order to meet the content requirements of the CSR-RLUG, the DAX 30 companies analysed report to a different extent. The range of published NFEs/NFBs extends from 8 to 93 PDF pages; the median is 13.5 PDF pages. In order to achieve a better comparability between graphically elaborately designed and text-heavy publications, the contents of the examined, self-contained NFEs/NFBs can be converted to standard pages of 1,500 characters per page. This results in a median of 37.5 standard pages for the 16 companies considered with a closed NFE/closed NFB – in a range of 13 to 191 standard pages.

The reason for the different scope of the NFEs and NFBs lies firstly in the differently detailed explanations of the contents. Secondly, the extent to which use is made of the possibility of referring to other contents of the management report. For example, the description of the business model – a mandatory disclosure according to the CSR-RLUG. Most of the analyzed DAX 30 companies use the possibility of the reference, some describe the business model only briefly and also refer to the management report. Only seven of them completely dispense with the reference and describe the business model completely in the NFB.

External examination of mandatory disclosures preferred
Although the DAX 30 companies show a wide range with regard to the scope of their non-financial disclosures, there is broad agreement on the content of the audit. 26 of the 27 companies analysed voluntarily have their NFE/NFB audited by an auditor. Three of the DAX 30 companies even have the auditor audited with sufficient certainty, i.e. with a positively formulated audit opinion and extensive auditing procedures. The rest chooses an audit with limited assurance for those companies that have their CSR reporting audited at all, as has been customary up to now.

The study by Kirchhoff Consult AG, Warth & Klein Grant Thornton AG and Wedel University of Applied Sciences with their detailed results can be found here.

Background to the CSR Directive Implementation Act

The CSR Directive Implementation Act adopted in Germany in March 2017 obliges large companies of public interest with more than 500 employees to provide information on material non-financial matters. Reporting is required for the first time for financial years beginning after December 31, 2016. It includes information on environmental, labour and social issues, respect for human rights and the fight against corruption and bribery.