No entry
without a voucher.
The sustainability statement forms part of the management report. It is subject to external assurance. For affected communities, the standard asks for effectiveness and measurable targets, not for the intention to do good. S3beleg supplies the figures, from schools in the catchment area of your own sites.
A speed camera is a matter of chance.
This is not.
Assurance of the sustainability statement is required by law. Someone will look, and that someone has to issue an opinion. Three steps lead from there to the provisions of the German Commercial Code.
Directive (EU) 2022/2464
What the statute says.
Not what somebody writes about it. The links lead exclusively to the official texts. The German provisions are given in the original; the translations of the headings are for orientation only.
| Provision | What it governs | Legal consequence |
|---|---|---|
| § 334 HGBAdministrative fines | Administrative offence in the event of breaches of the provisions on the management report and non-financial reporting. | Fine of up to 50,000 euro. In the cases of subsection 2 sentence 1 number 1, up to 500,000 euro. For capital-market-oriented companies, subsections 3 and 3a provide for considerably higher ceilings, up to ten million euro or five per cent of annual turnover. |
| § 335 HGBCoercive fines | Proceedings before the Federal Office of Justice where disclosure is not made, or not made in time. | Coercive fine from 2,500 to 25,000 euro. If the six-week period passes unused, the order is repeated, until disclosure has been made. |
| § 331 HGBMisrepresentation | Criminal offence for members of management and supervisory bodies who misrepresent or conceal the circumstances in the management report. Number 1 expressly names the management report including the non-financial statement. | Imprisonment of up to three years or a fine. Where committed recklessly, up to one year. |
For context: § 331 HGB presupposes a misrepresentation or concealment, not a thin evidence base. A figure identified and justified as an estimate is something different from an invented one. That is precisely why it pays to hold a document behind every disclosure.
The standard asks about effect.
Not about intention.
Most undertakings report their community engagement as running text with a donation figure. In two places the standard asks for something else.
Why local schools
belong here at all.
ESRS S3 is titled „Affected Communities”. Who falls within it is set out in the standard itself. The first case named there is the neighbourhood of your own sites.
„communities living or working around the undertaking’s operating sites, factories, facilities or other physical operations, or more remote communities affected by activities at those sites”
ESRS S3, paragraph 9(a) · Delegated Regulation (EU) 2023/2772, Annex I
An undertaking and a school in the same place are therefore not a contrived connection, but the case the standard describes.
One class. One school year.
Figures that can be examined.
You sponsor one school class in the catchment area of your site. We run the programme, measure before and after, and hand you the analysis in a form you can place before your auditor.
And what we do not.
A voucher supports an entry. It does not replace the decision whether to make the entry, nor the judgement whether it was right. The same applies here.
Status of this page: August 2026
The CSRD is in force as a Directive. The German transposition act, through which the provisions cited are extended to sustainability reporting, was still in the legislative procedure at the time of publication. Sections 331, 334 and 335 of the German Commercial Code already apply today to the management report and the non-financial statement.
The revised ESRS were adopted by the European Commission as a delegated act on 3 July 2026 and were most recently before the European Parliament and the Council for scrutiny. ESRS S3 remains a standard in its own right. First application is envisaged for the 2027 financial year, for undertakings with more than 1,000 employees and more than 450 million euro in turnover.
This page sets out the legal position in Germany and serves as information. It is not legal advice and not tax advice. For an assessment of your individual case, please turn to your statutory auditor, your tax adviser or your legal department.
Let us talk about
your location.
Tell us where you are based and how many classes you have in mind. We will look at which schools in your catchment area come into question, and we will tell you frankly whether the data fits your materiality assessment.