Statement:
Government Draft of a CSRD Implementation Law – Federal Government announces Review of opening up the Circle of Auditors
Statement by the Federal Council
On 17 October 2025, the Federal Council adopted the recommendations of its committees and proposed opening up the sustainability reporting audit market to independent providers of assurance services (BT-Drs. 21/2465, numbers 5 and 8). The reasons given for this include “capacity, expertise, and cost considerations,” strengthening competition, and avoiding further “concentration effects” in the auditing market.
Counterstatement by the Federal Government
In its counterstatement of 29 October, 2025 (BT-Drs. 21/2465), the federal government announced that it would examine opening up the auditing market, but pointed out that “the admission of independent providers of assurance services would (would) constitute a significant legislative intervention in established structures, as legal regulations on supervision, training, and the liability and sanction regime, among other things, would have to be adapted or newly created.”
WPK continues to oppose the Proposal
In its statement of 4 November, 2025, to the committees of the German Bundestag, the WPK continues to oppose the proposal.
In its counterstatement, the federal government itself states that the current group of companies required to report on sustainability is expected to decrease by around 75 to 80%. This means that there will be no bottlenecks or further concentration effects on the auditor market. Furthermore, there are still no independent providers of assurance services that are subject to the same professional and legal requirements as auditors, as required by Article 1(13)(c) of the CSRD Directive. The WPK refers once again to its position paper on the implementation of the CSRD dated June 21, 2024.
Furthermore, a combined audit of both the annual and consolidated financial statements and the sustainability report or consolidated sustainability report leads to synergy effects (for example, with regard to existing know-how from sustainability audits in previous years). This, in turn, has a positive effect on audit costs.
