Germany failed to transpose CSRD into its national legislation by the initial deadline of 6 July 2024. After missing the deadline and following the dissolution of the governing coalition, the initial draft transposition law became invalid. As of July 2025, the German Government is planning to simultaneously transpose the CSRD and the Stop the Clock Directive. As the latter deadline has been set for December 2025, it is expected that both pieces of legislation will be transposed into German law by the end of 2025.

The current version of the draft CSRD implementation law was disclosed by the Federal Ministry of Justice and Consumer Protection (BMJV) on the 10^th of July 2025. The draft envisaged the transposition on the “1:1 basis”, meaning that though member states have some room to deviate from the Directive, the German Government does not intend to add or modify any provisions different from the CSRD text. At the same time, the draft law introduces a transitional exemption for companies with between 501 and 1,000 employees, relieving them from reporting requirements for the 2025 and 2026 financial years. Such an exemption anticipates the anticipated adoption of the EU’s Omnibus package and seeks to prevent companies from investing in compliance efforts that may soon be reduced or even become unnecessary. Separate legislation is expected to address the implementation details for Waves 2 and 3 at a later stage.

As of August 2025, the German Government has not transposed the EU Corporate Sustainability Due Diligence Directive (CSDDD) into its national legislation. Based on the recent decision of the EU Council, which is subject to the approval by the European Parliament, the CSDDD transposition deadline is expected to be postponed by one year until 26 July 2028.

At the same time, similar requirements are already in force in Germany under its own Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz), which was adopted in 2021 and came into effect in 2023. This law applies to companies that are either headquartered in Germany or operate a branch there, provided they meet specific workforce thresholds:

• From 2023, this includes companies with 3,000 or more employees in Germany.

• Starting in 2024, the threshold was lowered to 1,000 employees.

Smaller businesses and foreign suppliers fall outside the scope of this legislation. As a result, they are not subject to oversight by the Federal Office for Economic Affairs and Export Control (BAFA) and are not liable for any related penalties. Nonetheless, these entities may still feel indirect effects of the law, for example, through compliance demands from larger companies within their supply chain.

The due diligence requirements extend beyond a company’s own operations to include its direct suppliers. In some cases, they also cover indirect suppliers, specifically when a complaint is filed or when the company has credible information indicating a risk of violations. The evidence of any wrongdoing may be based on the company’s own monitoring or on credible third-party reports, including from civil society. The law outlines a list of human rights and environmental standards that must be upheld, based on internationally recognised conventions.

The EU Whistleblower Protection Directive was transposed in Germany via the Law to improve the protection of whistleblowers and to implement the Directive on the protection of persons who report breaches of Union law (Hinweisgeberschutzgesetz). The law came into effect on June 2, 2023, and is currently in force.

The law requires that companies within its scope must set up internal reporting channels so that employees (as well as job applicants, ex-employees, whistleblower supporters and journalists) can report on illegal activities, provided such activities take place and become known to them in a professional context. The law also strictly bans any retaliation against whistleblowers. The law applies to all companies with 50 or more employees. Failure to comply with the law may result in fines ranging between EUR 10,000 and EUR 50,000.

The German Law covers a wider range of issues and is overall broader in scope than the EU Directive. Thus, it applies to whistleblowing concerning any violation of the German criminal laws, any laws protecting life, health, or bodily integrity of people or the rights of employees, as far as such violations are subject to fines (Bußgelder), laws on the rights of shareholders in companies with a holder capital (Aktiengesellschaften), and any corporate tax law violations.

The law requires that confidentiality be strictly maintained, and the identity of the whistleblower is protected. It also advised, but does not require, that anonymous reports are accepted and processed. At the same time, the law has been criticised by NGOs, calling it a "toothless tiger", for the poor and slow enforcement, as well as the lack of visibility and understanding among the potential whistleblowers. The German Government also failed to conduct an evaluation of how effectively the law is implemented. The Federal Ministry of Justice (BMJ) initially planned for mid-2025, however, it has been postponed until 2026.

The EU Directive on Transparent and Predictable Working Conditions was transposed into German law in June 2022, coming into effect on 1 August 2022. This piece of legislation envisages considerable practical changes for employers. Thus, it introduces a wide range of amendments to existing legal frameworks, including the Act on Proof of Employment Conditions, the Temporary Employment Act, the Part-Time and Fixed-Term Employment Act, and the Trade Regulation Act.

One of the key changes is the significant expansion of employers’ duty to provide written documentation outlining the terms and conditions of employment to their employees. The documentation must now cover the length of any agreed probationary period, how wages will be paid, rest breaks and rest periods, details of any on-call work, conditions under which overtime may be required, procedures for terminating employment, and additional documentation requirements for international assignments.

Changes to the Trade Regulation Act (Gewerbeordnung" (GewO)) also strengthen employee protections: employers may no longer charge workers for training if that training is required by law, a collective agreement, or a works agreement. Furthermore, training must take place during regular working hours. If trainings occur outside of those hours, they must still be counted and compensated as working time. Amendments to the Part-Time and Fixed-Term Employment Act (Teilzeit- und Befristungsgesetz) further specify that any probationary period in a fixed-term contract must be reasonable and proportionate to the length of the contract and the nature of the job.

In October 2024, Germany transposed the EU Directive on Adequate Minimum Wages via a statement published in the official gazette, confirming that its current Minimum Wage Act (MiLoG) and Collective Agreements Act (TVG) already meet the Directive’s requirements. As a result, no amendments were made to the existing legislation.

Currently, under German MiLoG law, every employee is entitled to receive at least the statutory minimum wage, calculated as a fixed hourly rate. As of January 2025, the rate made up EUR 12.82 per hour. In June 2025, the Minimum Wage Commission approved a gradual increase in the statutory minimum wage to EUR 13.90 on January 1, 2026, and EUR 14.60 on January 1, 2027. Certain categories of workers, however, remain expressly exempt from this entitlement. These are: individuals under 18 years of age who have not yet obtained a vocational qualification, persons who have been unemployed long-term during the first six months after starting a new job, and trainees undergoing vocational training.

In addition, in January 2025, the Minimum Wage Commission revised its rules of procedure, adding the Directive’s benchmark for adequate minimum wages set at 60% of the gross median wage for full-time employees as one of the factors to be considered when issuing recommendations on adjustments to the statutory minimum wage.

The original EU Posted Workers Directive was transposed in Germany via the Act on Mandatory Working Conditions for Workers Posted Across Borders and for Workers Regularly Employed in Germany (Arbeitnehmer-Entsendegesetz, AEntG). The updated EU Posted Workers Directive of 2018 was implemented through amendments to the AEntG that came into effect on 30 July 2020.

Before the transposition of the EU Directive, generally binding collective bargaining agreements in Germany applied to posted workers only in the construction sector. The changes resulting from the transition of EU rules significantly broadened this scope, extending such agreements to posted employees across other sectors. In addition, employers are now required to pay overtime premiums, grant hazard allowances, and provide benefits in kind, while long-term postings are subject to a wider range of working conditions. At present, these federally binding agreements cover industries such as construction, laundering services in the business-to-business sector, and specialist mining work in hard coal mines, as well as commercial laundry services, waste management (including street cleaning and winter road clearance), vocational training services under the Social Security Act, the meat processing sector, and nursing and care services.

Even in cases where no generally binding collective bargaining agreement applies to a posting, employers remain obliged to comply with the core statutory working conditions. These include adherence to the minimum wage, observance of maximum working hours, and the granting of at least the minimum annual leave required by law.

The third version of the EU Energy Performance of Buildings Directive (EPBD III) was transposed in Germany via the German Buildings Energy Act (Gebäudeenergiegesetz, GEG), which applies to both residential and non-residential buildings. The GEG envisages that:

• Since January 1, 2024, only heating systems based on at least 65% renewable energy may be installed in new buildings within new development areas.

• Longer transition periods are planned for new buildings constructed in vacant lots, as well as for existing buildings. This will enable better coordination of investment decisions with local heating planning. Municipalities nationwide must determine by mid-2028 at the latest (major cities by mid-2026) where heating networks or climate-neutral gas networks will be expanded in the coming years.

GEG does not require any specific technology or solution, so building owners can decide how they meet the 65% renewables obligation. Solutions may include connecting to a district heating network, installing electric heat pumps, using direct electric heating, employing hybrid systems that pair renewable heat with a gas or oil boiler, or implementing solar thermal heating. Under certain conditions, it is also permissible to install “H₂-ready” gas boilers, which can be converted to run entirely on hydrogen. Biomass-based heating or gas heating systems that can verifiably operate on renewable gases (where at least 65% of the fuel consists of biomethane, biogenic liquefied gas, or hydrogen) are also in line with the GEG.

From 2045 onwards, all fossil-based building heating must be stopped completely, and only renewable energy sources will have to be used.

As of August 2025, Germany has not yet transposed the fourth version of the Energy Performance of Buildings Directive, which EU member states must transpose it into national law by 29 May 2026. The German Government has stated that the NBRP is being developed; however, the consultation timeline has not yet been set. Therefore, there’s no publicly released German draft, and it is unclear if Germany is going to meet the EU deadline of in December 2025.

The EU Energy Efficiency Directive (EED) was transposed into German law via the Energy Efficiency Act (EnEfG), which was adopted by the German Parliament in September 2023. The EnEfG does not address the buildings and construction sector directly. Instead, it primarily applies to public authorities, companies, and data centres, among others, with obligations tied to energy consumption thresholds, energy or environmental management systems, waste‑heat utilisation, and efficiency reporting.

The initial EU Waste Framework Directive (WFD) was transposed in Germany via the Act to Promote Circular Economy and Safeguard the Environmentally Compatible Management of Waste (Kreislaufwirtschaftsgesetz, KrWG), adopted by the Parliament in February 2012. The amended WFD was transposed in July 2020 by updating Article 1 of the KrWG Act. In particular, the German KrWG requires that from 1 January 2020 onwards, preparation for the re-use, recycling and other material recovery of non-hazardous construction and demolition waste must cover at least 70% by weight. In addition, it requires that in the ‘design of work procedures, procurement or use of materials and consumer durables, in construction projects and other contracts, the German authorities must give preference to products that:

• Have been produced in resource-saving, energy-saving, water-saving, low-pollution or low-waste processes,

• Have been produced through preparation for re-use, or by recycling waste, in particular using recycled content, or from renewable raw materials,

• Are characterised by durability, repairability, re-useability and recyclability, or

• In comparison to other products, lead to less waste, or to lower-pollution waste, or are better suited to environmentally-compatible waste management.

In addition, under the German Circular Economy Act (KrWG), the German Commercial Waste Ordinance (Gewerbeabfallverordnung, GewAbfV) was adopted and came into effect in 2017. The GewAbfV applies to certain types of construction and demolition waste (Bau- und Abbruchabfälle). It requires that producers and holders of construction and demolition waste must collect, transport, and prioritise the following waste fractions separately for preparation for reuse or recycling: glass, plastics, metals, including alloys, wood, insulation material, bitumen mixtures, gypsum-based building materials, concrete, bricks, tiles and ceramics. If mixed construction and demolition waste is generated, it must be sent to a sorting facility that meets defined efficiency targets: at least 85% of the input must be sorted into separate fractions, and at least 30% must be recycled. Residual waste from sorting may be sent to energy recovery or, if that is not feasible, to disposal.

The German Building Electric Mobility Infrastructure Act (GEIG) is a law aimed at enhancing the uptake of electric vehicles through the installation of charging facilities in both commercial and residential buildings. It has been in force since 25 March 2021 and applies to new construction projects and major renovations. According to the law, all new residential buildings with five or more parking lots must be equipped with an electric cable connection for charging e-vehicles. For major renovations (over 25% of the total building area), the threshold is somewhat higher, at ten parking lots.

For new non-residential buildings, GEIG requires that electric cable wiring must be installed for every third parking lot in buildings with six or more parking lots, and that the parking area is equipped with at least one charging point. In refurbished buildings with ten or more parking lots, every fifth lot must have the electrical wiring and at least one charging point per parking area. In addition, from 1 January 2025, all non-residential buildings with 20 or more parking lots must be equipped with at least one electric charging point, regardless of whether they have been renovated or not. Failure to comply with GEIG may result in a fine of up to EUR 10,000.

The GEIG does not apply to certain cases. Small and medium-sized businesses (those with fewer than 250 employees and an annual turnover below EUR 50 million) are exempt if they primarily occupy and use their own buildings. There is also a cost-related exemption: if installing the required charging infrastructure would amount to more than 7% of the total renovation expenses for a non-residential building, the obligations under the GEIG do not apply. In addition, some public buildings are already subject to other legal frameworks and therefore fall outside the scope of the GEIG requirements.

The accessibility of residential and public buildings to people with disabilities, elderly people, and people with children in Germany is regulated by the German Equality Opportunities for Disabled Persons Act (BGG) and the Model Building Regulation (MBO).

The BGG came into effect on May 1, 2002, and was further amended on July 27, 2016. The law defines accessibility in the following manner: “Structural and other facilities, means of transport, technical consumer goods, information processing systems, acoustic and visual information sources and communication facilities, as well as other designed areas of life, are considered barrier-free if they can be found, accessed, and used by people with disabilities in the usual way, without particular difficulty, and generally without outside assistance. The use of aids necessary for the disability is permitted.” BGG contains specific provisions aimed at creating accessibility in the areas of construction and transport. Thus, it requires that Federal buildings, whether newly built, renovated, or extended, must be designed so that everyone, including people with disabilities, can use them. If the usual accessibility standards cannot be met, alternative solutions are acceptable as long as they provide the same level of access. Whenever construction work is carried out, authorities should also check other public areas of the building and remove any barriers where it is practical to do so and not overly expensive. Government agencies must assess how accessible their buildings are and prepare clear plans with timelines to address remaining barriers. When renting buildings for federal use, preference should be given to those that are already accessible or can be made accessible without unreasonable costs. Public spaces such as streets, squares, paths, and transport facilities should also be designed so that everyone can use them without difficulty.

The MBO requires that “In buildings with more than two apartments, the apartments on each floor must be accessible without barriers; this obligation can also be fulfilled by accessible apartments on several floors. In these apartments, the lounges, a toilet, a bathroom, the kitchen or the kitchenette and, where available, a terrace must be barrier-free”. In addition to the requirements for the residential buildings, the regulations also require that any public areas are barrier-free. In particular, this applies to:

• cultural, education and educational institutions,

• sports and leisure venues,

• public health service institutions,

• office, administrative and court buildings

• sales points, restaurants and accommodation establishments, and

• parking spaces, garages and toilet facilities.