ESRS in German: What Went Wrong in 2023 and What Now Applies with the ESRS 2026

In short: The revised ESRS (Delegated Regulation (EU) 2026/1563) have been in the Official Journal of the EU since Monday, 21 September 2026, in German as well. They enter into force on 10 November 2026 and apply at the latest to financial years starting on or after 1 January 2027. The German version is not the final word yet: the terminology proposals from DRSC and AFRAC could not be incorporated in time, and a corrigendum is planned for October/November 2026. Anyone who saw "policies" suddenly turn into "Strategien" (strategies) in 2023 knows why a closer look pays off.

What exactly has been live since 21 September?

On 21 September 2026 the EU published two delegated regulations in the Official Journal: Regulation (EU) 2026/1563 with the revised ESRS and Regulation (EU) 2026/1560 with the Voluntary Standard (VS). Both are available in all official languages, including German.

The key facts:

• Entry into force: The ESRS 2026 enter into force on 10 November 2026, the VS already did on 24 September 2026.
• Application: at the latest for financial years beginning on or after 1 January 2027.
• Option for 2026: For financial years beginning in 2026 you can apply the previous ESRS, the revised ESRS, or the previous ESRS with individual reliefs from the new version. According to the IDW (the German Institute of Public Auditors) you have to state which version you used.
• Scope: The number of mandatory datapoints drops by more than 60 percent, the total number of datapoints by more than 70 percent.

We have summarised what changes in substance in "From ESRS to Omnibus ESRS". This article is about the language.

Looking back: the translation chaos of the 2023 ESRS

The first version of the ESRS (Set 1) came as Delegated Regulation (EU) 2023/2772 of 31 July 2023. Only with this legal act were the standards translated into the official languages of the EU. The German Federal Ministry of Justice asked the DRSC (the German accounting standard setter) for feedback on the German version, and in September 2023 the DRSC sent a long list of possible translation errors, collected from companies that have to report under the ESRS.

The problem was not a matter of style. The ESRS work with defined terms. If two different English terms get the same German word, the obligation behind them blurs. Three examples show this well.

Example 1: "Policies" became "Strategien"

The ESRS distinguish between Strategy (strategy and business model, SBM) and Policies (governed by the minimum disclosure requirements MDR-P). The 2023 German version translated both as "Strategie" or "Strategien" (strategy, strategies). The DRSC pointed out that the earlier CSR Directive had already translated "policies" as "Konzepte", and that companies could not report a large part of their policies in the sense of the CSRD if "policy" is read strictly as "strategy".

Before (2023): In the remuneration disclosures of ESRS 2, the German text said the company provides information "über die Strategien zu nachhaltigkeitsbezogenen Anreiz- und Vergütungssystemen" (on the strategies for sustainability-related incentive and remuneration schemes). The English original simply said "remuneration policies".

The risk in practice: Anyone reading the literal translation looks for a "remuneration strategy", which often does not exist as a separate document, instead of describing the existing remuneration scheme. Conversely, chapters on policies can end up with strategic statements of intent where the standard means a binding policy. Haufe, a German specialist publisher, puts it in a nutshell: if you describe a strategy where a binding policy is required, you risk not meeting the disclosure requirement.

After: With the corrigendum to the German version of 9 August 2024, "policies" in the glossary sense is "Konzepte". The DRSC and AFRAC term list (as of June 2026) consistently gives "Policy / Policies" as "Konzept / Konzepte".

But careful: "Policy" is not always a company policy. In ESRS E1 and E4, "policy" often means public policy, for example "climate-related public policy goals" or national biodiversity policy. There, "politische Ziele" or "politische Leitlinien" (political goals or guidelines) is correct. The DRSC/AFRAC list explicitly calls the translation in ESRS E4 para 32(b) and AR 24 inconsistent. A blunt search and replace would therefore have created new errors.

Example 2: "Eigene Belegschaft" instead of "Arbeitskräfte des Unternehmens"

In 2023, ESRS S1 was called "Eigene Belegschaft" in German. The DRSC criticised this: in German labour law, "Belegschaft" presupposes an employment contract. But by "own workforce" the ESRS mean more, namely also non-employees such as agency workers and self-employed people.

Before: Anyone taking "Belegschaft" literally may report headcount, accidents or training hours only for their own employees and leave out agency work.

After: Since the 2024 corrigendum the standard is called "Arbeitskräfte des Unternehmens" (the undertaking's workforce). "Employees" was made more precise as well: "Beschäftigte" became "Arbeitnehmer". The distinction between employees and non-employees is now visible in German.

Example 3: "gegebenenfalls" sounds voluntary

The English ESRS often use "if applicable", "where relevant" or "shall include, if applicable". The German version frequently turns this into "gegebenenfalls". The DRSC/AFRAC list calls this "unfortunate": according to the Duden dictionary, "gegebenenfalls" also stands for "possibly" or "perhaps" and gives too strong an impression of being voluntary. What is meant is: the disclosure is mandatory as soon as it applies.

Before: "Das Unternehmen gibt gegebenenfalls folgende Informationen an" (the undertaking discloses the following information, if applicable) is easily read as "we can leave that out".

After: The project group proposes wording such as "soweit einschlägig" or "sofern relevant" (where applicable, where relevant). The published German version of the ESRS 2026, however, still uses "gegebenenfalls" throughout. The proposals have not been incorporated yet. The announced corrigendum may change that.

The most important terms compared

The corrigendum of 9 August 2024 covered around 287 pages and affected all twelve standards. According to the DRSC, the EU Commission adopted about 75 percent of the suggested changes. Nothing changed in substance, it was purely a translation correction.

Where things stand now

The profession learned from 2023. DRSC and AFRAC, the standard setters from Germany and Austria, set up a joint project group on translation in July 2024. It developed term lists for ESRS 1 and 2 (October 2024), the E standards (April 2025) and S1 and G1 (November 2025), and on 26 June 2026 submitted a systematically reviewed list of German technical terms to the EU Commission.

The timing still was not enough. The Commission adopted the revised ESRS on 3 July 2026 and published them on 21 September 2026. According to the DRSC, the translation comments could not be taken into account in this short time. A corrigendum to the German versions of the ESRS 2026 and the VS is planned for October/November 2026.

A look at the text shows how necessary that is. In ESRS S4 (consumers and end-users), disclosure requirement S4-1, para 9, the German text has two almost identical sentences directly after each other: "Es hat anzugeben, ob diese Strategien bestimmte Gruppen (...) abdecken." and right after it "Es hat anzugeben, ob diese Konzepte bestimmte Gruppen (...) abdecken." So the old and the new translation of "policies" stand side by side in the Official Journal. And the general disclosures on policies (GDR-P) still speak of a "Menschenrechtspolitik" where a company policy is meant.

For you this means: The German ESRS 2026 are published and binding, but individual terms can still change within a few weeks. It is the same situation as in 2023, only announced in advance.

What this means for your report

1. One term, one meaning. Define an internal glossary before you write: which English ESRS term is rendered with which German word. The DRSC/AFRAC list is a good basis for this.
2. No mixing of versions. For 2026 you may choose between the old and the new version or combine them. If parts of the report are written with Set 1 terms and others with ESRS 2026 terms, it looks like two different requirements to readers and auditors. Haufe describes exactly this case: reports that are worked on over months carry different states of terminology because corrections arrived at different times.
3. Keep EN and DE cleanly separated. Many teams work with English templates, group guidelines or auditor questions in English and write the report in German. This seam is exactly where "strategy instead of policy" errors arise. In Germany the sustainability report becomes part of the management report.
4. Plan for the corrigendum. If you switch to the ESRS 2026 now, plan a short terminology check after the announced corrigendum, before the report goes to the auditor.
5. Keep an eye on the legal status. The Omnibus package ("stop the clock") has postponed the second wave by two years. In Austria the NaBeG has applied since February 2026, in Germany the CSRD implementation act is still in the legislative process.

Bringing your existing report into the official terminology

Until now this meant: going through the report paragraph by paragraph, checking terms against the official version, looking up references and adjusting everything by hand. Now that the official German translation of the ESRS 2026 exists, you can do this with Glacier AI: you have your existing report translated with the correct, official ESRS terminology instead of reworking it manually.

Want to see what that looks like with your report? Book a demo of Glacier AI.

FAQ

Are the ESRS 2026 officially available in German?

Yes. Delegated Regulation (EU) 2026/1563 was published in the Official Journal of the EU on 21 September 2026 in all official languages, including German. A corrigendum to the German version has been announced for October/November 2026.

When do the revised ESRS apply?

They enter into force on 10 November 2026 and apply at the latest to financial years starting on or after 1 January 2027. For financial years beginning in 2026 you can choose between the old version, the new version, or the old version with individual reliefs, and you have to state which version you used.

Is "policies" translated as Strategien or Konzepte in German?

In the sense of the ESRS glossary it is "Konzepte". The first German version from 2023 said "Strategien", which was corrected on 9 August 2024. Where "policy" means public policy, for example climate or biodiversity goals of states, "Politik" or "politische Leitlinien" is correct.

Why is ESRS S1 no longer called "Eigene Belegschaft"?

Because "Belegschaft" presupposes an employment contract under German law. But ESRS S1 also covers agency workers and self-employed people. Since the 2024 corrigendum the standard is therefore called "Arbeitskräfte des Unternehmens".

Do I have to rewrite my report after the announced corrigendum?

A translation corrigendum does not change the obligations in substance. But you should align the terms in your report with the corrected version so that it stays consistent and unambiguous for auditors.

Where can I find a reliable English/German term list?

DRSC and AFRAC jointly publish lists of the most important ESRS technical terms with a recommended German translation, most recently in June 2026. They are freely available on the DRSC website.

Want to see what that looks like with your report? Book a demo of Glacier AI.