{"id":4031,"date":"2026-08-19T09:34:45","date_gmt":"2026-08-19T09:34:45","guid":{"rendered":"https:\/\/verso.de\/blog\/the-cost-of-mistakes-in-reporting-and-implementing-sustainability\/"},"modified":"2026-09-30T12:39:36","modified_gmt":"2026-09-30T12:39:36","slug":"the-cost-of-mistakes-in-reporting-and-implementing-sustainability","status":"publish","type":"post","link":"https:\/\/verso.de\/en\/blog\/the-cost-of-mistakes-in-reporting-and-implementing-sustainability\/","title":{"rendered":"The cost of mistakes in reporting and implementing sustainability"},"content":{"rendered":"\t
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19.08.2026<\/div>\n\t\t\t\t\t\t\t\t\t\t\t\t\n\t\t\t\t\t\t

ESG sanctions at a glance: the cost of mistakes in reporting and supply chain obligations<\/h1>\n\n\t\t\t\t\t\t\t\t\t\t\t\t\t

\n\t\t\t\t\t\t\t\tA slap on the wrist and, if it becomes public, a brief outcry from the public: until a few years ago, companies didn’t have to worry too much if they put sustainability on the back burner or engaged in greenwashing. The Omnibus package does little to change that: the EU has pushed back deadlines and reduced the number of companies affected, but it has not abolished the sanctions.\t\t\t\t\t\t\t<\/p>\n\t\t\t\t\t\t\n\t\t\t\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\n\t\t\t<\/div>\n\t\t<\/div>\n\t<\/section>\n\t\n\n\n\t

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Companies that breach ESG and supply chain obligations risk fines in the millions, penalties calculated as a percentage of annual turnover, seized goods or exclusion from public contracts, depending on the regulation. The EU Omnibus package made some rules less strict in 2026 and narrowed the group of companies they apply to. This article shows which sanctions apply under the CSRD, CSDDD, LkSG, CBAM, EUDR, PPWR, DPP and EmpCo, and from when.<\/p>\n

As of September 2026. This article reflects the EU Omnibus I package, the planned reform of the LkSG and the latest postponement of the EUDR. This information is editorial content that should not be construed as legal advice. VERSO accepts no liability. <\/em><\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n\n
ESG sanctions at a glance: possible sanctions, companies affected and start date by regulation (as of September 2026)<\/caption>\n
Regulation<\/th>\nPossible sanctions<\/th>\nWho is affected?<\/th>\nFrom when?<\/th>\n<\/tr>\n<\/thead>\n
CSRD<\/th>\nPlanned under the HGB: fines of up to \u20ac10 million or 5% of annual turnover (capital market-oriented companies), prison sentences of up to 3 years<\/td>\nMore than 1,000 employees and over \u20ac450 million net turnover<\/td>\nOnce the German implementation act enters into force (legislative process ongoing)<\/td>\n<\/tr>\n
CSDDD<\/th>\nUp to 3% of global net turnover, civil liability under national law<\/td>\nMore than 5,000 employees and over \u20ac1.5 billion net turnover<\/td>\nApplies from 26 July 2029<\/td>\n<\/tr>\n
LkSG<\/th>\nPreviously up to \u20ac8 million or 2% of global annual turnover, exclusion from public procurement; in future only for serious violations<\/td>\n1,000 or more employees in Germany<\/td>\nIn force since 2023, reform in the legislative process<\/td>\n<\/tr>\n
EU ETS<\/th>\n\u20ac100 per tonne of CO\u2082e without an allowance (adjusted for inflation)<\/td>\nOperators of installations covered by emissions trading<\/td>\nIn force<\/td>\n<\/tr>\n
CBAM<\/th>\nSame as EU ETS per missing certificate, revocation of declarant status<\/td>\nImporters of 50 tonnes or more of CBAM goods per year<\/td>\nDefinitive phase since 1 January 2026<\/td>\n<\/tr>\n
EUDR<\/th>\nAt least 4% of annual EU turnover, confiscation of goods, import bans, exclusion from public procurement<\/td>\nOperators and traders handling relevant commodities<\/td>\n30 Dec 2026 (large\/medium), 30 June 2027 (micro\/small)<\/td>\n<\/tr>\n
PPWR<\/th>\nFines of up to \u20ac200,000 under the German VerpackDG, distribution bans, public register entries<\/td>\nManufacturers, importers and distributors of packaging<\/td>\nSince 12 August 2026<\/td>\n<\/tr>\n
EmpCo<\/th>\nWarning letters, cease-and-desist claims; fines of up to \u20ac50,000 or 4% of the affected annual EU turnover<\/td>\nAll companies making environmental claims to consumers<\/td>\nSince 27 September 2026<\/td>\n<\/tr>\n
DPP (ESPR)<\/th>\nFines (level set nationally), withdrawal and recall, import bans, exclusion from public procurement<\/td>\nManufacturers and companies placing the relevant product group on the market<\/td>\nBattery passport from 18 Feb 2027, other product groups to follow<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\t\t\t\t\n\t\t\t\t\t\t\t<\/div>\n\t\t\t\n\t\t<\/div>\n\t<\/section>\n\n\t\n\n\n\n\t
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Stress-free CSRD compliance<\/h2>\n\t\t\t\t\t\n\t\t\t\t\t\t\t\t\t\t\t

Make CSRD as easy as possible: Our new CSRD Suite provides tools and support for every stage of CSRD compliance.<\/p>\n\t\t\t\t\t\t\t\t\t<\/div>\n\n\t\t\t\t\t\t\t\t\t

\n\t\t\t\t\t\t\t\t\t\t\t\t\t\n\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tGet to know the CSRD Suite<\/span><\/a>\n\t\t\t\t\t\t\n\t\t\t\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t\t\t\t<\/div>\n\t\t<\/div>\n<\/section>\n\n\t\n\n\n\t
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What sanctions apply for breaches of the CSRD, EU Taxonomy and SFDR?<\/h2>\n\t\t\t\t\n\t\t\t\t\t\t\t\t\t

There is no EU-wide, uniform set of sanctions for the CSRD. Each member state decides how to penalise errors in sustainability reporting. In Germany, this will be governed by the CSRD Implementation Act, which is still going through the legislative process. Until it enters into force, companies that were already required to report remain subject to the HGB rules on the non-financial statement. The government draft is based on the existing criminal and administrative penalty provisions in \u00a7331<\/a> and \u00a7334<\/a> HGB. In figures, this means:<\/p>\n