IFRS and German GAAP, clearly compared
This site compares the key standards of international accounting (IFRS/IAS) with their counterparts in German commercial law (HGB) – concise, with legal references and clear worked examples. It is aimed at students, preparers, advisers and anyone who wants to place the differences between the two systems quickly.
The traffic-light system shows at a glance how far IFRS and HGB diverge on a topic: red = high, amber = medium, green = low divergence. Use the search and filters to find a specific standard, keyword or HGB section; each card leads to a detail page with a full worked example.
Traffic-light system: High divergence Medium divergence Low divergence
IFRS — IFRS 15
Revenue is recognised under the five-step model: (1) identify the contract, (2) identify the separate performance obligations, (3) determine the transaction price, (4) allocate it to the performance obligations, (5) recognise revenue as each obligation is satisfied.
- Performance obligations are identified separately (distinct goods or services).
- Variable consideration (bonuses, discounts, returns) is estimated and included in the transaction price.
- Revenue is recognised either over time or at a point in time.
- Extensive disclosure requirements (disaggregation of revenue, contract assets and contract liabilities).
German GAAP (HGB)
§ 252 HGB§ 253 HGB§ 255 HGB§ 246 HGB
Realisation principle (§ 252 (1) No. 4 HGB): revenue is recognised only once the good has been delivered or the service rendered and beneficial ownership has passed.
- § 252 (1) No. 4 HGB: the realisation principle.
- § 255 HGB governs the measurement of production cost for long-term production.
- § 246 HGB: the completeness principle.
- Long-term construction contracts: HGB generally permits only the completed-contract method, whereas IFRS requires recognition over time.
▶ Key differences
- No five-step model; no requirement to disaggregate revenue.
- Variable consideration is treated far more restrictively (imparity principle).
- Long-term contracts: no partial profit is recognised before acceptance (completed-contract).
- No requirement to separate individual performance obligations within a bundle.
- Far fewer disclosure requirements in the notes.
IFRS — IFRS 16
Lessees apply a single on-balance-sheet model and recognise almost all leases as a right-of-use asset and a corresponding lease liability. The only exemptions are short-term leases and leases of low-value underlying assets.
- At commencement, the right-of-use asset is measured at cost (the present value of the lease payments).
- After initial recognition the lease liability is measured at amortised cost using the effective interest method.
- The right-of-use asset is measured at cost less accumulated depreciation and accumulated impairment losses.
- Recognition exemptions (election): short-term leases (≤ 12 months) and low-value assets; the related payments are then expensed on a straight-line basis.
- Lessors continue to classify leases as either finance or operating leases.
German GAAP (HGB)
§ 246 HGB§ 247 HGB§ 266 HGB§ 285 HGB
German GAAP contains no dedicated leasing standard. Recognition follows beneficial (economic) ownership: the leased asset is recognised by the lessee if substantially all risks and rewards are attributed to it. In practice the assessment follows the tax leasing decrees; operating leases stay off-balance-sheet.
- § 246 (1) HGB: assets are attributed according to beneficial (economic) ownership.
- § 247 (2) HGB: recognition within non-current assets only where the lessee is the beneficial owner.
- Leases are classified as finance or operating leases; the attribution follows the tax leasing decrees and may differ from the IFRS assessment.
- Operating lease payments are expensed on a straight-line basis by the lessee; other financial commitments are disclosed in the notes under § 285 No. 3 HGB.
▶ Key differences
- Under German GAAP operating leases remain off-balance-sheet (no right-of-use asset and no lease liability for the lessee).
- No single lease definition; attribution follows the tax leasing decrees rather than a control-based concept.
- IFRS 16 typically increases total assets and changes EBITDA/EBIT as well as leverage ratios.
- Considerably lower transparency under German GAAP; essentially only a note disclosure under § 285 No. 3 HGB.
IFRS — IAS 16
Property, plant and equipment is measured either at cost or under the revaluation model. It is depreciated systematically over its useful life.
- Accounting policy choice: the cost model or the revaluation model (fair value).
- Component approach: significant parts of an asset are depreciated separately.
- Impairment write-downs only where the asset is impaired (IAS 36 impairment test).
- Subsequent costs are capitalised when future economic benefits are probable.
- Decommissioning (asset retirement) obligations are included in the cost of the asset (IAS 37).
German GAAP (HGB)
§ 253 HGB§ 255 HGB§ 268 HGB
Property, plant and equipment is carried at acquisition or production cost less depreciation. No upward revaluation above cost is permitted.
- § 253 (1) HGB: acquisition/production cost is the measurement ceiling.
- § 253 (3) HGB: systematic depreciation over the useful life.
- § 255 HGB: mandatory components of production cost.
- § 268 (2) HGB: a fixed-asset movement schedule (Anlagenspiegel) is a required disclosure.
▶ Key differences
- The revaluation model (fair value above cost) is not permitted under German GAAP.
- The component approach is not mandatory; HGB allows the whole asset to be depreciated as a single unit.
- For non-current assets, an impairment write-down is required only where the impairment is expected to be permanent (§ 253 (3) sentence 5 HGB).
- Tax depreciation periods (AfA tables) carry greater practical weight than under IFRS.
IFRS — IAS 38
Internally generated intangible assets in the development phase must be capitalised once specific criteria are met. Research expenditure is expensed as incurred.
- Mandatory capitalisation in the development phase once the six criteria are met (IAS 38.57).
- Goodwill from business combinations: capitalised and not amortised (impairment-only testing under IAS 36).
- Optional revaluation model for intangible assets traded in an active market (rarely applicable).
- Extensive disclosure requirements by class of intangible asset.
German GAAP (HGB)
§ 248 HGB§ 253 HGB§ 255 HGB
Under German GAAP, internally generated intangible fixed assets may be capitalised (an option since BilMoG 2009), except internally generated goodwill. Purchased (derivative) goodwill must be capitalised.
- § 248 (2) HGB: an option to capitalise internally generated intangible fixed assets.
- § 255 (4) HGB: purchased goodwill must be capitalised and amortised systematically over its useful life.
- § 253 (1) HGB: cost ceiling; no revaluation model.
▶ Key differences
- No mandatory capitalisation in the development phase – only an option under § 248 (2) HGB.
- Internally generated goodwill may not be capitalised under German GAAP.
- Purchased goodwill: HGB requires systematic amortisation, whereas IFRS applies impairment-only testing (no amortisation).
- Capitalised internally generated intangibles are subject to a restriction on distribution (dividend block) under § 268 (8) HGB.
IFRS — IAS 2
Inventories are measured at the lower of cost and net realisable value. The LIFO method is prohibited.
- Comparison measure: net realisable value (NRV).
- Cost formulas: FIFO or weighted average (LIFO prohibited).
- Cost of conversion: fixed and variable production overheads must be included based on normal capacity.
- A reversal of a previous write-down is mandatory when NRV recovers (capped at cost).
German GAAP (HGB)
§ 253 HGB§ 256 HGB§ 255 HGB
Inventories follow the strict lower-of-cost-or-market principle (§ 253 (4) HGB). LIFO and FIFO are both permitted. Production cost under § 255 HGB has partly different inclusion options.
- § 253 (4) HGB: the strict lower-of-cost-or-market principle for current assets.
- § 256 HGB: the LIFO and FIFO cost formulas are both permitted.
- § 255 (2) HGB: an option to include reasonable portions of material and production overheads in production cost.
- Reversal of a write-down once the reason for it ceases to apply (§ 253 (5) HGB).
▶ Key differences
- LIFO is permitted under HGB but prohibited under IAS 2 (can lead to materially different inventory values).
- Production cost: HGB makes certain overheads optional, whereas IAS 2 requires production overheads to be included.
- Benchmark for the write-down: HGB uses the exchange/market price or fair value, IFRS uses net realisable value (NRV).
- Reversal once the reason ceases: mandatory under both HGB and IFRS (comparable in this respect).
IFRS — IAS 19
Defined benefit pension plans are measured using the projected unit credit method. Actuarial gains and losses are recognised directly in other comprehensive income (OCI).
- Projected unit credit method: future salary increases and staff turnover must be taken into account.
- Discount rate: the market yield on high-quality corporate bonds.
- Actuarial gains and losses (remeasurements): recognised in OCI, outside profit or loss.
- Service cost and net interest cost are recognised in profit or loss.
- Plan assets must be offset against the obligation.
German GAAP (HGB)
§ 249 HGB§ 253 HGB§ 266 HGB
Pension provisions are measured under § 253 HGB using the average market interest rate of the past 10 years. There is no OCI; all changes go through profit or loss.
- § 249 (1) HGB: a provision must be recognised.
- § 253 (2) HGB: discounting at the average market rate of the past 10 financial years (for pension obligations), published by the Deutsche Bundesbank.
- § 266 (3) HGB: provisions are presented on the equity-and-liabilities side of the balance sheet.
- Measurement is usually based on actuarial methods (e.g. the projected unit credit method).
▶ Key differences
- Discount rate: HGB uses a 10-year average vs. IFRS the current market rate – sometimes leading to material measurement differences.
- German GAAP has no OCI; all actuarial effects go through profit or loss.
- The transition difference from first-time BilMoG application may be built up over up to 15 years (Art. 67 EGHGB).
- Offsetting against plan assets is permitted under HGB only on the narrow conditions of § 246 (2) sentence 2 HGB.
IFRS — IAS 37
A provision is recognised when a present obligation is probable (more than 50%), an outflow of resources is probable and a reliable estimate can be made. It is measured at the best estimate.
- Criteria: a present obligation, probability > 50%, and a reliable estimate.
- Measurement: best estimate (expected value for a large population; most likely amount for a single obligation).
- Long-term provisions must be discounted.
- Contingent liabilities are disclosed in the notes only (not recognised on the balance sheet).
- Restructuring provisions: only where there is a detailed plan and the decision has been communicated.
German GAAP (HGB)
§ 249 HGB§ 253 HGB
Provisions under § 249 HGB are recognised for uncertain liabilities and onerous (pending) contracts. They are measured at the settlement amount (§ 253 (1) sentence 2 HGB).
- § 249 (1) HGB: mandatory for uncertain liabilities and onerous pending contracts.
- § 253 (1) sentence 2 HGB: measured at the settlement amount required according to prudent commercial judgement (including future price and cost increases).
- § 253 (2) HGB: provisions with a remaining term > 1 year are discounted at the average market rate of the past 7 financial years.
- § 249 (2) HGB: pure expense provisions have generally been prohibited since BilMoG.
▶ Key differences
- HGB: settlement amount including future cost increases; IFRS: best estimate at the reporting date.
- Provisions for onerous contracts are recognised under both HGB and IAS 37, though the recognition and measurement details may differ.
- Discounting: HGB uses the Bundesbank 7-year average rate vs. IFRS a current rate matched to the term.
- Restructuring provisions: similar in principle, but IFRS has more detailed recognition conditions.
IFRS — IAS 36
An annual impairment test for goodwill and intangible assets with an indefinite useful life. Where indicators exist: compare the carrying amount with the recoverable amount (value in use or fair value less costs of disposal).
- Goodwill: a mandatory annual impairment test (no amortisation).
- Recoverable amount: the higher of value in use (DCF) and fair value less costs of disposal.
- Cash-generating units (CGUs) are the unit of assessment.
- A reversal of impairment is required for all assets except goodwill.
German GAAP (HGB)
§ 253 HGB
Scheduled depreciation and impairment write-downs under § 253 HGB. There is no separate impairment concept based on CGUs, and goodwill is amortised systematically.
- § 253 (3) sentence 5 HGB: an impairment write-down for non-current assets only where the impairment is expected to be permanent.
- § 253 (4) HGB: impairment write-down for current assets (strict lower-of-cost-or-market principle).
- § 253 (5) HGB: a write-down must be reversed once the reason for it ceases (except for goodwill).
▶ Key differences
- No CGU concept; impairment is generally assessed for the individual asset.
- Goodwill: systematic amortisation under HGB; under IFRS no amortisation, only an impairment test.
- For non-current assets, HGB writes down only on a permanent impairment, whereas IFRS does so as soon as indicators are present.
- Reversal of impairment: mandatory under HGB (except goodwill); under IFRS mandatory except for goodwill.
IFRS — IFRS 9
Classification by business model and contractual cash-flow characteristics into FVTPL, FVOCI or amortised cost. An expected-credit-loss (ECL) model is used for impairment.
- Categories: amortised cost, FVOCI (with/without recycling) and FVTPL.
- ECL model: a three-stage approach – a 12-month ECL is recognised already at initial recognition.
- Hedge accounting: a strict framework with effectiveness requirements.
- Derivatives: always measured at fair value (even without a hedging relationship).
German GAAP (HGB)
§ 253 HGB§ 255 HGB§ 340e HGB
German GAAP distinguishes between non-current and current assets. Measurement is at (amortised) cost under the lower-of-cost-or-market principle. There is no ECL model; allowances are recognised only when a concrete default risk exists.
- § 253 (1) HGB: cost is the measurement ceiling.
- § 253 (3)/(4) HGB: the lower-of-cost-or-market principle, depending on classification as a non-current or current asset.
- § 340e (3) HGB: trading-book financial instruments of credit institutions are measured at fair value less a risk discount.
- § 254 HGB: the formation of valuation units (the German-GAAP form of hedge accounting).
▶ Key differences
- No ECL model; HGB recognises an allowance only on an actual default or an identifiable risk.
- No fair-value measurement of debt instruments held as non-current assets (except the trading book of credit institutions).
- Derivatives, as pending transactions, are generally not recognised under HGB; where their fair value is negative, a provision for onerous contracts must be recognised.
- Hedge accounting under HGB uses valuation units (§ 254 HGB) and is less formalised than under IFRS 9.
IFRS — IAS 12
Temporary-difference approach: deferred taxes on temporary differences between IFRS carrying amounts and tax bases. Deferred tax assets on loss carryforwards are recognised where utilisation is sufficiently probable.
- Temporary-difference approach: a balance-sheet comparison of the IFRS amount with the tax base.
- Deferred tax assets on loss carryforwards where future utilisation is probable.
- Deferred taxes are not discounted.
- Measured at the tax rate expected to apply when the difference reverses.
- Deferred taxes on items recognised in OCI are also recognised in OCI.
German GAAP (HGB)
§ 274 HGB§ 306 HGB
§ 274 HGB: a temporary-difference approach (since BilMoG). Deferred tax liabilities must be recognised; recognising a net deferred tax asset is optional (including loss carryforwards, limited to 5 years).
- § 274 (1) HGB: deferred tax liabilities must be recognised; recognising a net deferred tax asset is an option.
- § 274 (1) sentence 4 HGB: loss carryforwards are included only to the extent utilisation is expected within the next five years.
- § 268 (8) / § 285 HGB: a restriction on distribution (dividend block) and note disclosures.
- § 306 HGB: deferred taxes in the consolidated financial statements.
▶ Key differences
- Recognition of deferred tax assets is optional under HGB but mandatory under IFRS – this can noticeably affect the effective tax rate.
- HGB: a net (total-difference) view with offsetting; IFRS: more granular recognition and offsetting rules.
- A restriction on distribution under § 268 (8) HGB for a net deferred tax asset; there is no equivalent in IFRS.
- Recognition of loss carryforwards is capped at 5 years under HGB, whereas IFRS looks to the probability of future profits.
IFRS — IAS 1
A set of IFRS financial statements comprises: a balance sheet, a statement of comprehensive income (profit or loss + OCI), a statement of changes in equity, a statement of cash flows and the notes. There is no rigidly prescribed format, but minimum disclosures apply.
- Required components: balance sheet, profit or loss + OCI, statement of changes in equity, statement of cash flows and notes.
- OCI (other comprehensive income): equity changes recognised outside profit or loss (e.g. revaluations, currency translation).
- Option: present comprehensive income in a single statement or in two (profit or loss and OCI separately).
- Minimum line items in the balance sheet; additional items may be added.
- A going-concern assessment is mandatory.
German GAAP (HGB)
§ 243 HGB§ 264 HGB§ 266 HGB§ 275 HGB
The annual financial statements (§ 242 HGB) comprise a balance sheet and an income statement; for corporations these are supplemented by the notes and (where applicable) a management report. There is no OCI concept and no mandatory statement of changes in equity in the separate financial statements.
- § 243 HGB: prepared in accordance with the German principles of orderly accounting (GoB).
- § 264 (1) HGB: corporations: balance sheet + income statement + notes + (where applicable) management report.
- § 266 HGB: a prescribed balance-sheet format (account form).
- § 275 HGB: a prescribed income-statement format (nature-of-expense or cost-of-sales method, in vertical form).
▶ Key differences
- No OCI concept under HGB; all income effects flow through profit or loss.
- No mandatory statement of changes in equity in the HGB separate financial statements.
- A statement of cash flows is required in the separate financial statements only for capital-market-oriented entities; in the consolidated accounts it is mandatory.
- Rigid formats (§ 266, § 275 HGB) vs. the flexible IFRS minimum framework.
- The management report is a separate mandatory instrument under HGB; IFRS has no direct equivalent.
IFRS — IFRS 18
IFRS 18 replaces IAS 1 and applies to reporting periods beginning on or after 1 January 2027 (earlier application permitted). It restructures the income statement into defined categories with two new mandatory subtotals, requires disclosure of management-defined performance measures (MPMs), and sets out principles for aggregation and disaggregation. It is a presentation and disclosure standard only – recognition, measurement and the bottom-line result are unchanged.
- Five categories in the income statement: operating, investing, financing, income taxes and discontinued operations.
- Two new mandatory subtotals: operating profit and profit before financing and income taxes.
- Management-defined performance measures (MPMs): disclosed in a single note with a reconciliation to the most comparable IFRS subtotal.
- Principles for aggregation and disaggregation, including meaningful line-item labels (avoiding uninformative "other" items).
- Replaces IAS 1; mandatory for periods beginning on or after 1 January 2027 (earlier application permitted). EU endorsement follows in a separate process.
German GAAP (HGB)
§ 265 HGB§ 266 HGB§ 275 HGB
German GAAP governs presentation through fixed statutory formats (balance sheet § 266, income statement § 275 using the total-cost or cost-of-sales method) with general principles in § 265. There is no mandatory "operating profit" subtotal and no MPM regime.
- § 266 HGB: statutory balance-sheet format.
- § 275 HGB: income statement in vertical form, either the total-cost or the cost-of-sales method; prescribed line items down to the net result.
- § 265 HGB: general presentation principles (consistency, prior-year comparatives, limited subdivision/aggregation of items).
- Since BilRUG there is no separate "result of ordinary activities"; an operating-profit subtotal is not required.
- Alternative measures, if shown, appear in the management report (§ 289 HGB), outside the financial statements and without a prescribed reconciliation.
▶ Key differences
- IFRS 18 requires the operating-profit and profit-before-financing-and-income-taxes subtotals; HGB has no comparable mandatory subtotal.
- IFRS 18 regulates management-defined performance measures (MPMs) including a reconciliation in the notes; HGB has no equivalent rule.
- IFRS 18 is principle-based (categories plus aggregation/disaggregation principles); HGB uses fixed formats (§ 266, § 275).
- Presentation and disclosure differences only: recognition, measurement and the net result are unaffected.
IFRS — IAS 7
A required component of IFRS financial statements. Three sections: operating activities (direct or indirect method), investing activities and financing activities.
- Option: the direct or the indirect method for operating activities.
- Interest and dividends: classification options across the three sections.
- The cash fund = cash and cash equivalents.
- Disclosure of significant non-cash transactions.
German GAAP (HGB)
§ 264 HGB§ 297 HGB
A statement of cash flows under HGB/DRS 21 is mandatory for consolidated financial statements and for capital-market-oriented entities. Its structure and method are largely analogous to IAS 7.
- § 264 (1) sentence 2 HGB: a statement of cash flows is required for capital-market-oriented corporations (separate financial statements).
- § 297 (1) HGB: a required component of the consolidated financial statements.
- DRS 21: the German Accounting Standard that sets out the detailed rules.
- Structure: operating, investing, financing – analogous to IAS 7.
▶ Key differences
- No HGB requirement in the separate financial statements of non-capital-market-oriented entities; IFRS always requires one.
- Partly different classification of interest and dividends (DRS 21 vs. the IAS 7 options).
- Overall few substantive differences; the structure is largely harmonised.
IFRS — IFRS 3
The acquisition method is the only permitted method. All identifiable assets and liabilities are recognised at fair value. Goodwill = consideration transferred minus the fair value of the net assets.
- The only permitted method: the acquisition method.
- Identifiable intangible assets must be recognised separately (e.g. customer relationships, brands).
- Goodwill: not amortised; tested for impairment annually.
- Transaction costs: expensed as incurred.
- Contingent consideration (earn-outs): recognised at fair value.
German GAAP (HGB)
§ 301 HGB§ 309 HGB§ 255 HGB
Capital consolidation under § 301 HGB (the acquisition/revaluation method). A positive difference (goodwill) is presented as goodwill (Geschäfts- oder Firmenwert) and amortised systematically.
- § 301 HGB: capital consolidation using the revaluation (acquisition) method.
- § 309 HGB in conjunction with § 246 (1) sentence 4 HGB: goodwill is amortised systematically over its useful life.
- § 255 (4) HGB: purchased goodwill in the separate financial statements.
- Hidden reserves and charges are revealed as part of the revaluation.
▶ Key differences
- Goodwill: systematic amortisation under HGB vs. an impairment test only under IFRS.
- Intangibles acquired in the combination: HGB tends to recognise fewer of them separately (e.g. customer relationships/brands).
- Transaction costs: expensed under IFRS; under HGB partly included in the cost of the investment.
- Earn-out arrangements: measured at fair value under IFRS; HGB allows more latitude in estimation and recognition.
IFRS — IAS 1 / Rahmenkonzept
IFRS has no separate balance-sheet line for "deferral items" (Rechnungsabgrenzungsposten). Prepaid expenses and deferred income are presented within the relevant balance-sheet items as prepayments (other receivables) or deferred income (other liabilities).
- Allocation follows the accrual basis (IAS 1.27 f.).
- Asset-side deferrals: as prepayments within current or non-current assets.
- Liability-side deferrals: as deferred income within liabilities.
- Loan discount: no separate balance-sheet line; the effective-interest method spreads the difference automatically.
German GAAP (HGB)
§ 250 HGB§ 252 HGB§ 266 HGB
§ 250 HGB requires a separate balance-sheet line for prepaid expenses (ARAP, asset side) and deferred income (PRAP, liability side). A loan discount may optionally be capitalised as an asset-side deferral.
- § 250 (1) HGB: an asset-side deferral for expenditure before the reporting date that represents expense for a defined period thereafter.
- § 250 (2) HGB: a liability-side deferral for income received before the reporting date that represents revenue for a defined period thereafter.
- § 250 (3) HGB: an option to capitalise a loan discount (the difference on a liability).
- § 266 HGB: ARAP and PRAP as separate balance-sheet items (assets letter C / liabilities letter D).
▶ Key differences
- HGB shows deferral items as a separate balance-sheet line; IFRS allocates these amounts to the ordinary receivable or liability items.
- Loan discount: HGB allows optional capitalisation under § 250 (3); IFRS has no separate item and spreads it automatically via the effective-interest method.
- Presentation differences can affect balance-sheet ratios (e.g. the current ratio).
IFRS — IFRS S1 / IFRS S2
The ISSB (International Sustainability Standards Board) has issued IFRS S1 (general sustainability disclosures) and IFRS S2 (climate-related disclosures). Both build on the TCFD framework and are geared to decision-usefulness for investors (financial materiality).
- IFRS S1: general requirements (governance, strategy, risk management, metrics and targets).
- IFRS S2: climate-related disclosures, including physical and transition risks and Scope 1/2/3 greenhouse-gas emissions.
- Focus on financial materiality (effects on enterprise value); no mandatory double materiality.
- Adoption into national law is jurisdiction-dependent; not yet mandatory in the EU to date.
German GAAP (HGB)
§ 289b HGB§ 289c HGB§ 289d HGB§ 315b HGB
The EU CSRD (Corporate Sustainability Reporting Directive) is gradually replacing the previous non-financial statement under §§ 289b ff. HGB. Reporting follows the ESRS (European Sustainability Reporting Standards).
- § 289b HGB: the non-financial statement (previous law) for certain large, capital-market-oriented entities.
- § 289c HGB: minimum content requirements (environmental, employee and social matters, human rights, anti-corruption).
- § 289d HGB: recognised frameworks may be used.
- § 315b HGB: the consolidated non-financial statement.
- CSRD/ESRS: a phased introduction with mandatory external assurance; the German transposition into the HGB was most recently not yet complete.
▶ Key differences
- Double materiality: ESRS/CSRD requires disclosures on impacts on people and the environment AND on financial risks; IFRS S1/S2 focus on financial materiality.
- The ESRS are considerably more extensive and granular than IFRS S2.
- Assurance: CSRD initially requires limited assurance; for IFRS S1/S2 the assurance requirement depends on the jurisdiction.
- Placement: CSRD requires it to be embedded in the (group) management report; IFRS S1/S2 are more flexible.
No matching standard found.