The 2025/26 reporting season is the most terminologically demanding I have worked through since IFRS landed in 2005. Three first-time CSRD reports crossed my desk this cycle, three different sustainability teams—and underneath all of them, the same structural problem: there is no single document that tells you what an ESRS term should say in English.
Why this season is different
The first wave of CSRD reporters—companies previously caught by the NFRD—had to publish their initial CSRD-compliant sustainability statements covering the 2024 fiscal year, which put the work in front of translators in 2025. Large EU companies that clear two of three size thresholds report on fiscal 2025 in 2026. So the demand isn’t theoretical; it’s a live commissioning queue, and the German teams driving it are discovering that their carefully built German wording does not map cleanly onto the English their international investors expect.
I translate these reports myself—just me, the standards, and a termbase. That vantage point makes one thing obvious that gets lost in the agency pitch decks: an ESRS report in English is a regulatory document. Get a term wrong and you haven’t made a stylistic slip; you’ve altered what a disclosure says you are obligated to do. A CSRD translation platform put it plainly—an incorrect translation can materially alter the meaning of a disclosure, creating significant legal and reputational risk. That is the right altitude to work at.
The three-glossary problem
Here is the citable core of the whole issue. EFRAG wrote the ESRS in English, and that English text is the authoritative original. A German company translating its CSRD report for international investors therefore has to reconcile three competing authoritative vocabularies at once—the EFRAG source text (English), the EU Official Journal’s German legal rendering, and the established GRI/TCFD equivalents (English) that analysts already know—and no single mapping document bridges all three.
None of the three is sufficient on its own, and that is the part teams underestimate.
- The EFRAG English source is the authoritative text—the standards were written in it. But it isn’t what your German sustainability team drafted from. They worked from the German.
- The EU Official Journal German version is the legal text your report has to be consistent with domestically—yet it is demonstrably imperfect. Germany’s Accounting Standards Committee (ASCG/DRSC) submitted a formal analysis of the German ESRS Set 1 to the Federal Ministry of Justice in September 2023 and recommended extensive linguistic changes. So you cannot treat the German Official Journal text as a single source of truth; you cross-check it against EFRAG’s English.
- GRI and TCFD vocabulary is what your international readers have been trained on for a decade. It overlaps with ESRS terms—but the overlapping words frequently carry different scope. Borrow the familiar word and you import the wrong definition.
So how do I set the hierarchy? For any term with a binding ESRS definition, the EFRAG English text wins—full stop. The German Official Journal renders the same concept and I keep my English consistent with that German wherever the report has to align domestically. GRI/TCFD equivalents come last: useful for readability and for cross-referencing, never as the source of a definition. When a familiar GRI word would mislead, I keep the ESRS term and add a translator’s note flagging the divergence.
Ten ESRS terminology traps
These are the terms where the obvious carry-over fails most reliably. German original, the official English, and why the easy version breaks.
- doppelte Wesentlichkeit → double materiality. Not “dual materiality” used loosely, and not GRI/TCFD materiality. ESRS 1 paragraph 37 defines exactly two dimensions—impact materiality and financial materiality—each a separate assessment. Anchor to ESRS 1, not to the framework your reader happens to know.
- Wertschöpfungskette → value chain. Never “supply chain.” ESRS 1 paragraph 63 extends the value chain to indirect business relationships, upstream and downstream; “supply chain” covers direct contractual links only. The wrong word shrinks the reporting perimeter.
- betroffene Stakeholder → affected stakeholders. Not bare “stakeholders” or “interested parties.” ESRS 1 paragraph 22 gives the term a bounded definition that grounds due-diligence and materiality obligations. Generalize it and you lose the regulatory hook.
- Sorgfaltspflicht → due diligence. In the UN/OECD sense of ESRS 1 paragraph 59—identify, prevent, mitigate, account for negative impacts on people and environment—not financial or M&A due diligence. German spans both senses; English readers will default to the financial one unless you anchor it.
- Angabepflicht / Angabepflichten → disclosure requirement(s). Not “reporting obligation” or “mandatory information.” ESRS uses Disclosure Requirements as named, numbered units (the DR codes). Translate the label, not a paraphrase, or your cross-references stop resolving.
- Wesentlichkeitsanalyse → materiality assessment. Not “materiality analysis.” “Assessment” is the ESRS term of art; “analysis” reads as a generic study and breaks consistency with the standard’s own language.
- wesentliche Auswirkungen, Risiken und Chancen → material impacts, risks and opportunities. The phrase travels as a unit, abbreviated IROs. “Chancen” is “opportunities,” never “chances”; “Auswirkungen” is “impacts,” not “effects.”
- Übergangsplan → transition plan. Specifically the transition plan for climate change mitigation under ESRS E1. Not “transformation plan,” not “transitional plan.” It’s a defined deliverable with its own disclosure content.
- vorgelagert / nachgelagert → upstream / downstream. Not “preceding/subsequent” or “supplier-side/customer-side.” These are the value-chain direction terms and have to match the value-chain definition above.
- Taxonomie-Konformität → Taxonomy alignment. Not “Taxonomy conformity” or “compliance.” “Aligned” vs. “eligible” is a precise EU Taxonomy distinction; the wrong noun blurs a number that auditors check.
Why “value chain” isn’t “supply chain”—and five more concept shifts
Some of these traps aren’t just wrong words; they’re concept shifts that quietly strip the regulatory meaning and hand the client a liability. Six worth understanding in full.
Value chain vs. supply chain
ESRS 1 paragraph 63 connects material impacts, risks and opportunities through direct and indirect business relationships, upstream and downstream. The confusion between value chain and supply chain is a named, recognized interpretation risk in ESRS reporting—the distinctions are crucial. Render “Wertschöpfungskette” as “supply chain” and you truncate the perimeter to direct suppliers, excluding downstream distributors, customers and indirect shareholding relationships that the standard pulls in. The report then understates the company’s own obligations.
Due diligence in the human-rights sense
“Sorgfaltspflicht” lands on an English reader as financial due diligence unless you steer it. ESRS 1 paragraph 59 means the process of identifying, preventing, mitigating and accounting for negative impacts on people and the environment across operations and value chains. Same two English words, completely different obligation. I anchor it on first use and let the termbase hold the line after that.
Affected stakeholders, not stakeholders
ESRS 1 paragraph 22 defines affected stakeholders as individuals or groups whose interests are or could be affected—positively or negatively—by the undertaking’s activities and its direct and indirect business relationships across the value chain. GRI’s looser “stakeholders” doesn’t carry that boundary, and the boundary is exactly what grounds the due-diligence and materiality work.
Double materiality vs. single materiality
This is the one I flag explicitly for any audience trained on ISSB or TCFD. ESRS double materiality requires disclosure of matters that are material from an impact perspective alone, with no financial consequence for the undertaking—a requirement absent from the ISSB’s single-materiality framework, which targets investor decision-making exclusively. If your English report reads as if only financially material matters were disclosed, you’ve misdescribed the framework you reported under. A translator’s note earns its keep here.
Taxonomy alignment vs. eligibility
“Aligned” and “eligible” are distinct EU Taxonomy states attached to hard percentages. German drafts sometimes blur them, and a careless English pass collapses both into “compliant.” That changes a reported number’s meaning—the kind of error an auditor catches and a reader sues over.
Transition plan as a defined deliverable
Under ESRS E1 the transition plan for climate change mitigation has prescribed content. Translate it as a generic “transformation plan” and you signal something looser than the standard requires. The label is part of the compliance, not decoration.
Terminology management across reporting years
None of this survives one report unless it’s stored. Professional ESRS work needs both translation-memory systems and a dedicated, version-controlled terminology database—not ad-hoc CAT-tool use. The reasoning is concrete: terminology management is what delivers consistent technical terms, accurate regulatory definitions, and consistency across multiple reports.
In practice I build an ESRS termbase in Trados Studio (Across when the client’s environment requires it), structured by ESRS standard and paragraph reference, with the German Official Journal rendering and the EFRAG English in parallel fields and a note field for the divergences above. The translation memory from the 2025 first report then feeds the 2026 follow-up, so wording that Legal approved once doesn’t get relitigated.
Versioning matters more here than in any other domain I work in, because the standard itself moves. EFRAG has already issued corrigenda—the DRSC corrections covered typos, wrong references and other obvious errors. And the 2025 Omnibus simplification revises the standards further: each standard ships a Log of Amendments, and a separate markup shows changes to the Glossary in Annex II compared with the original delegated act. So the termbase has to be tagged to the specific regulatory generation your client’s report is filed under. A 2024-fiscal-year report and a 2025-fiscal-year report may not share the same official glossary, and the termbase has to know which one applies.
Data confidentiality on CSRD documents
Unpublished sustainability metrics, draft transition plans and materiality analyses are price- and reputation-sensitive before disclosure. I handle them exactly the way I handle embargoed financial figures: EU server location, a clear NDA structure, and no upload to US-based machine-translation engines. That last point is not negotiable on CSRD work—a draft transition plan pasted into a public MT box is a leak, full stop. If you want detail on how data is held, my privacy page covers it.
To be clear about what I don’t offer: I’m not a court-sworn translator. If your filing needs a certified or sworn translation, that’s the domain of court-sworn colleagues, and I’ll say so rather than improvise. ESRS reporting translation is a different specialism, and it’s the one I do.
From practice: a 35,000-word first report
Anonymized and NDA-clean: a German industrial group, first CSRD report, roughly 35,000 words of sustainability statement plus the usual annexes. Here is how that runs.
- Terminology kickoff with the sustainability team. Before a word is translated, we sit down over the ESRS terms specific to their material topics and agree the English. This is where “Wertschöpfungskette,” “Sorgfaltspflicht” and the materiality vocabulary get locked, against EFRAG paragraphs, not against habit.
- Reference gathering. Prior ESG communications, any English the company has already published, the corporate wording guide, and—crucially—which regulatory generation of the standard the report is filed under.
- Translation against the live termbase. The terms decided in the kickoff are enforced by the tool, not by my memory, so consistency holds across 35,000 words and across whoever reviews them.
- Sustainability-team review of content, then Legal sign-off. Two distinct reviews with distinct jobs: the sustainability team checks substance, Legal checks exposure. Wrong terminology is a measurable legal and reputational risk, so Legal’s pass is the real gate.
- EFRAG-correction buffer. Time held back at the end for late corrigenda or glossary changes landing during the project window.
The fallible parts are predictable: the kickoff getting skipped to save a week (it never saves a week), reference documents arriving after translation has started, and no one owning the final review. Build the buffer in and those stop being emergencies.
Checklist before you commission
What IR, sustainability and communications teams should settle with the translator before awarding a CSRD job:
- Glossary status: which ESRS regulatory generation are you filing under—the 2023 delegated act or the Omnibus-revised standards? The termbase has to match.
- Reference documents: prior English ESG reports, corporate wording guide, and any approved term list, handed over up front, not mid-project.
- Review ownership: who signs off on content, and who in Legal signs off on exposure. Name them before the start.
- Confidentiality terms: NDA in place, EU data handling confirmed, and an explicit no-public-MT rule for drafts.
- Time buffer: schedule space for late EFRAG corrections and a real terminology kickoff, not a same-week scramble.
If you’re commissioning or QA-checking an English CSRD report this season and want it handled as the compliance document it is, see what I offer on services or get in touch via contact. The terminology is where these reports go wrong—and it’s the part that’s entirely preventable.