Since the 2024 fiscal year, large companies and listed SMEs in the EU have been reporting in accordance with the Corporate Sustainability Reporting Directive (CSRD). Content that was previously voluntary disclosure is now part of the management report, and is subject to audit. This also affects what a translation has to accomplish. If wording inadvertently gets toned down, this can distort a statement that is subject to disclosure.
What the CSRD means for different language versions
The CSRD (EU Directive 2022/2464) requires detailed disclosures on environmental, social, and governance matters. The European Sustainability Reporting Standards (ESRS) specify what information is to be disclosed and how it should be presented. They were developed by the European Financial Reporting Advisory Group (EFRAG) and have been applicable since July 2023 in accordance with the Delegated Regulation. Effective from 2028, non-EU companies conducting business in the EU will also be subject to these rules.
In line with ESRS requirements, the sustainability statement must be prepared in the same language as the management report. Other language versions are subject to equally strict requirements regarding content and review. In some markets, a version in the local language is also required by law.
Where translations can go wrong
The German version of the ESRS is 287 pages long. In August 2024, the European Commission adopted formal corrections (corrigenda), which were implemented by EFRAG. The issues primarily concerned editorial errors and terminology.
Here’s an example from this round: The English term “workforce” had been translated as “Belegschaft”. The German term is more narrowly defined and excludes temporary workers and those who are self-employed. As a result, this linguistic decision had altered the scope of the reporting requirement.
It’s a similar case with modal verbs. The word “shall” does not indicate a recommendation. Anyone who translates it as “sollte”, meaning “should”, makes a requirement less binding without changing a single number. This also applies to voluntary commitments: In German, the phrase “We commit to” quickly turns into a non-binding statement of intent when phrased in the passive voice, and that is precisely what gives rise to accusations of greenwashing.
What it takes to produce successful translations
When precise terminology is essential, processes have to be equally precise. They address exactly where potential sources of error lie: inaccurate data sources, players from outside the field, and a lack of oversight. That is why the following process steps are essential for every report translation we undertake:
- The glossary is set up before writing the first line. We align ESRS, GRI, and the GHG Protocol with your existing corporate terminology and clarify any ambiguous terms with your specialist departments. You can find more information on our Terminology Management page.
- Translations are handled by professional translators with a background in ESG. After all, it is necessary to be familiar with the frameworks in order to be able to use the terms correctly.
- A second expert then reviews the content, such as key figures, data references, and information on methodology. For texts that are subject to audit, linguistic revision alone is not enough.
- The final step involves reconciling all language versions, as well as the layout, footnotes, tables, and digital markup. We adapt number formats to the target language; the values themselves remain unchanged.
Certifications and data security
Sustainability reports may contain inside information pursuant to Article 7(4) of the MAR. The resulting obligations for insiders go far beyond the mere duty of confidentiality. Our processes for projects involving insider information are correspondingly strict. They are part of a comprehensive set of guidelines that forms the foundation of our work:
- ISO 17100 for the translation process, including review by a second qualified professional
- ISO 9001 for quality management throughout the company
- ISO 18587, when parts are first machine translated and then reviewed
- TISAX for information security
- Data protection in accordance with the GDPR in the EU
- Compliance management based on ISO 37301
Here are the Certifications at a Glance.
How can we help you?
If you send us your report from the previous year, we will review the different language versions for discrepancies in ESG terminology. Just send an email to info@leinhaeuser.com .

