ESG / Sustainability Officer

The Sustainability Officer (often labelled ESG Officer, Head of Sustainability or CSRD Officer) is responsible for fulfilling the reporting obligations of the Corporate Sustainability Reporting Directive (CSRD, Directive 2022/2464/EU of 14.12.2022). In Germany the CSRD was transposed through amendments to §§ 289b, 289c and 315c of the German Commercial Code (HGB). The management report is extended by a dedicated sustainability statement that must follow the European Sustainability Reporting Standards (ESRS) under Articles 19a and 29a of the Accounting Directive. Delegated Regulation (EU) 2023/2772 enacted ESRS Set 1 with the twelve standards ESRS 1, ESRS 2, ESRS E1 to E5 (climate, pollution, water, biodiversity, circular economy), ESRS S1 to S4 (own workforce, value chain workers, affected communities, consumers) and ESRS G1 (governance).

Applicability rolls out in three waves. Wave 1 covers former NFRD entities (listed companies above 500 employees) from financial year 2024. Wave 2 captures all large undertakings as defined by § 267 HGB (meeting at least two of: 25 million EUR balance sheet, 50 million EUR turnover, 250 employees) from financial year 2025. Wave 3 picks up listed SMEs from financial year 2026 with an opt-out until 2028. Third-country undertakings with more than 150 million EUR EU turnover follow from 2028. The EU Omnibus initiative of February 2025 has tabled changes to scope and timing; until formally adopted the existing rules remain binding.

The sustainability officer coordinates the double materiality assessment (impact and financial under ESRS 1 Chapter 3), gathers the roughly 1,100 ESRS data points across the twelve standards, and acts as the interface to the financial auditor since the report is subject to mandatory assurance under § 324b HGB with limited assurance now and reasonable assurance in the medium term. Reports follow the European Single Electronic Format (ESEF) with XBRL tagging against the ESRS taxonomy. In parallel the officer aligns the EU Taxonomy Regulation 2020/852, the SFDR Regulation 2019/2088 for financial institutions and the LkSG supply chain duties, which requires structured data flows across Finance, Procurement, HR and Operations.

Unlike the data protection officer or the AML officer, the sustainability officer is not codified in a single statute. The obligation arises indirectly from the management board's responsibility for the management report under § 264 HGB, the risk monitoring duty under § 91 Para. 2 AktG, the mandatory audit under § 324b HGB and the D&O liability exposure for incorrect reporting. Because the sustainability statement forms part of the management report and is subject to mandatory assurance, most in-scope companies establish a dedicated C-level or senior leadership role. Audits initially follow ISAE 3000 (Revised) or the forthcoming European Sustainability Reporting Assurance Standard (ESRAS). The supervisory board oversees sustainability reporting under § 107 Para. 3 AktG and the audit committee receives extended duties under § 107 Para. 4 AktG.

Typical qualifications include a business or engineering background, expertise in greenhouse gas accounting under the GHG Protocol and ISO 14064, fluency with the ESRS standards, and ideally a certification such as GRI Certified Sustainability Professional, IFRS Sustainability Reporting Certificate or CSE Certified Sustainability Practitioner. Multi-year experience in data management, risk analysis and stakeholder engagement is standard. External appointments are common in mid-market Wave 2 companies, often as interim sustainability officer at 2 to 4 days per month, while Wave 1 groups usually maintain internal teams embedded in Finance, Strategy or a dedicated sustainability unit, typically supported by an ESG steering committee with CFO, CHRO and COO.