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Institut der Wirtschaftsprüfer in Deutschland e.V.

IDW

The IDW is the voluntary association representing public auditors and auditing firms throughout Germany.

Lobbying Activity

German auditor association demands clearer EU travel VAT rules

14 Oct 2025
Topic — The Commission is revising VAT rules for travel agents and passenger transport.
Message — The IDW requests clear definitions for taxable persons and travel services. They demand uniform application of the margin scheme across the EU. They also seek explicit rules for VAT disclosure and deduction rights.123
Why — Standardized rules would simplify auditing and reduce compliance risks for businesses.4
Impact — Non-EU tour operators could lose tax advantages if rules are tightened.5
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Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

10 Jul 2025 · CSRD and sustainability omnibus

Meeting with Angelika Niebler (Member of the European Parliament)

11 Jun 2025 · EU Omnibus Package

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

10 Jun 2025 · CSRD omnibus/ESRS revision/assurance guidelines

German Auditors Seek Greater Clarity on Taxonomy Reporting Simplification

26 Mar 2025
Topic — This consultation proposes amendments to simplify EU Taxonomy reporting and reduce corporate costs.
Message — The group requests clarification on how the 10% materiality threshold applies to business activities. They suggest extending these exemptions to initial eligibility assessments and adopting a principles-based approach.12
Why — Flexible thresholds would significantly reduce the complexity and cost of sustainability audits.3
Impact — Investors may lose transparency regarding potentially harmful activities hidden within non-material portfolios.4
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Meeting with Markus Ferber (Member of the European Parliament)

13 Mar 2025 · Omnibus

Meeting with Axel Voss (Member of the European Parliament)

20 Nov 2024 · Audits

German auditors urge GDPR updates for cloud and AI

7 Feb 2024
Topic — Review of the EU General Data Protection Regulation's application six years after its entry.
Message — The IDW suggests clarifying that certifications should legally limit the scope of audit rights. They demand measures to prevent the misuse of data access rights for litigation. They also call for an adapted legal basis for artificial intelligence.123
Why — Auditors would face lower compliance costs and reduced exposure to compensation claims for formal violations.45
Impact — Citizens would find it more difficult to obtain full copies of their data from organizations.6
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

24 Jan 2024

Beigefügt finden Sie die Stellungnahme des Instituts der Wirtschaftsprüfer in Deutschland e.V. (IDW) zur Initiative "Unternehmen in Europa: ein Rahmen für die Unternehmensbesteuerung (BEFIT)". / Please see attached pdf file.
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German auditors urge simplified EU sustainability reporting framework

30 Nov 2023
Topic — A European Commission initiative to reduce corporate reporting burdens by 25%.
Message — The IDW proposes a general 'leading principle' for sustainability reporting to clarify complex rules. They also suggest aligning the companies included in financial and sustainability reports. Finally, they request exemptions for first-time taxonomy reporters.123
Why — Standardization and alignment would reduce administrative expenses and simplify audit procedures for companies.45
Impact — Investors and environmental groups would lose access to year-on-year comparative sustainability data initially.6
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

28 Nov 2023 · Corporate Sustainability Due Diligence

Response to Adjusting size criteria for inflation in the Accounting Directive to define micro, small and medium-sized enterprises

5 Oct 2023

Overall, we support the proposal as it makes fundamental sense to adjust the monetary thresholds regularly in line with inflation to prevent those undertakings and groups whose business volume has not actually expanded from becoming subject to more extensive reporting, auditing and disclosure requirements simply due to the impact of inflation. For further considerations please refer to the attached pdf-document.
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German auditors urge clearer rules for EU sustainability reporting

7 Jul 2023
Topic — The Commission is consulting on the first set of European Sustainability Reporting Standards.
Message — The IDW requests clearer guidance on materiality and a leading principle for sustainability reporting. They emphasize the need for harmonization with international standards and other EU laws like the SFDR. Additionally, they advocate for sufficient implementation time to ensure high-quality external audits.123
Why — Precise rules and adequate timelines would reduce the risk of issuing qualified audit opinions.4
Impact — Financial market participants may lose access to critical data needed for regulatory compliance.5
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Response to VAT in the Digital Age

31 Mar 2023

Unsere Stellungnahme reichen wir beigefügt als pdf-Datei ein./Please see attached pdf file.
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German auditors urge BEFIT alignment with global tax rules

26 Jan 2023
Topic — The European Commission is consulting on a common framework for corporate income taxation.
Message — The IDW recommends a far-reaching alignment of the common tax base with global minimum tax rules. They argue that formulaic profit allocation should reduce the need for overlapping anti-abuse regulations.12
Why — This would avoid a juxtaposition of regulations that counteracts the goal of lower compliance costs.3
Impact — Member states might lose the ability to use tax measures as short-term instruments for economic policy.4
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German auditors urge EU to distinguish tax evasion from planning

11 Oct 2022
Topic — EU initiative targeting professionals who facilitate tax evasion and aggressive tax planning.
Message — The IDW demands a clear distinction between illegal tax evasion and legal tax planning. They argue that closing loopholes is a legislative duty and not for advisors. They suggest evaluating existing rules before proposing new ones.123
Why — This prevents auditors from facing conflicting legal risks of professional sanctions or liability.4
Impact — EU member states face continued tax base erosion while waiting for evaluations.5
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German auditors urge DEBRA simplification to protect corporate investment

28 Jul 2022
Topic — A proposal reducing tax bias favoring debt financing over equity contributions.
Message — IDW requests removing rules on negative equity allowances and clarifying documentation requirements for anti-abuse measures. They also suggest a three million euro threshold to decrease the administrative burden on taxpayers.12
Why — These changes would lower compliance costs and prevent excessive bureaucratic hurdles for companies.3
Impact — The public interest in tax fairness might suffer if anti-abuse rules are weakened.4
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Response to Cyber Resilience Act

20 May 2022

IDW very much welcomes the Call for Evidence “Cyber Resilience Act” and thanks you for the opportunity to comment on the Commission's legislative plans. We share Madam President’s view that Europe should strive to become a leader in cybersecurity (CS). However, we are convinced that achieving this goal is predicated upon amending the current legislative framework in the field of cybersecurity to strengthen the cyber resilience of infrastructures, products and services for European businesses and consumers. CS in businesses, public administrations and for consumers using digital products and services (dP&S) cannot be achieved by the technical security of dP&S alone: effective CS needs to be embedded in the business model and hence in the information management systems and processes of the businesses. CS for consumers involves the interaction of people with such dP&S, a prerequisite for which is a secure digital eco system safeguarded by effective information security management systems (ISMS). These ISMS need to be designed according to EU CS requirements regarding their technical implementation as well as operational policies and procedures. However, without independent and expert third-party verifica-tion of EU compliance of those systems it will be difficult to enforce compliance. For this reason, the verification of EU CS compliance of those businesses by independent assurance experts is a cornerstone of the EU strategy of having the EU become a leader in CS. A key prerequisite for a high level of effective CS is the further development of the EU CS frameworks and requirements for the ICT industry, operators of critical infrastructure and public administrations – that is “suitable criteria for CS”. These need to be set forth in EU legislation, including by empowering an appropriate European Authority to set forth principles-based requirements. Such “suitable criteria” are also a prerequisite for assurance practitioners to perform assurance engagements to verify compliance with such requirements. However, users of dP&S will only understand benefits of the independent assurance on compliance with CS requirements if they have access to the results of those assurance engagements. The transparency of these results would create a level playing field for all producers and providers of dP&S in the European market. The European, and hence the German auditing profession, has been conducting assurance engagements of dP&S for many decades based on internationally recognised assurance standards. Many such engagements were performed for globally well-known cloud service providers (e.g. Azure Cloud, AWS) and software providers such as SAP. On a national level, IDW has established assurance pronouncements in this area using the internationally recognised assurance standard ISAE 3000 (Revised). In this context, we would like to propose the following measures for the Commission's further course of legislative action: • Further developing regulatory CS requirements for the ICT industry in technical security and organisational aspects by using established frameworks with policies and procedures, e.g. Cyber Security Act, ISMS. • Recommendation of the Commission for voluntary assurance engagements of digital products and associated services (including cloud service) using ISAE 3000 (Revised) or equivalent standards, as a basis for assurance on the design and actual implemen-tation of (cyber) security measures. • Amendment of the existing Cyber Security Act 2019: acknowledging statutory auditors as a "certified assurance body". Please find enclosed the relevant technical IDW Standards in the attachment "Annex" IDW PS 860 IDW PH 9.860.1 IDW PH 9.860.2 IDW PH 9.860.3 n.F. (10.2021) IDW PS 880 IDW PS 880 n.F. (01.2022) Prüfungsbericht Deloitte & Touche SAP – source: Deloitte & Touche SAP AG Walldorf - PDF Free Download (docplayer.org)
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Response to Strengthening the quality of corporate reporting and its enforcement

4 Feb 2022

We support the EC in looking at the entire corporate reporting ecosystem. We acknowledge the EC’s stance that – if any – “smarter” as opposed to “heavier” regulation makes sense. Better harmonization (e.g., regarding mandatory auditor rotation at 10 years or allowed non-audit services (NAS) and their definition) will bring efficiencies for EU companies and auditors with EU-wide activities. It should, however, not increase the regulatory burden; this would prevent auditors to enter the PIE audit market. Some parties are suggesting the Wirecard case justifies stricter rules for PIE audits. However, information in respect of ongoing investigations so far, suggest it was a very particular case of fraud; it is not representative, nor does it prove systemic shortcomings within the audit profession. Flaws identified in the German framework were rooted in an incomplete transposition of the Audit Regulation (the establishment of audit committees; the nomination of a competent authority acc. to article 7 Audit Regulation). Corporate governance: Management could be required to establish and report on internal control systems, esp. related to anti-fraud, and to report on its assessment of going concern. These requirements ought to be flanked by related legal duties of the entity’s supervisory body and by the obligation to seek an auditor’s assurance on these reports as well as on the entity’s CG statement. Reporting: A stepped approach to the introduction of sustainability reporting and monitoring (as well as assurance) is needed to ensure all affected parties have sufficient time to address new reporting requirements appropriately. In this context, we also stress again the imperative to improve the connectivity between the financial statements and sustainability reporting considerably. Statutory audit: Overall, the EU regulatory framework is effective and consistent. The numerous financial statements that are audited show that audits overall are being performed reliably. In particular, the rules for independence are robust. Non-audit services do not appear to be an issue in the Wirecard case. Further assurance engagements to an audit client do not bear a risk for independence. Indeed, other assurance engagements (e.g., on compliance management systems, CSR reporting) provide more information upon which auditors of financial statements can draw when performing their audits. We observe only singular situations where the choice of PIE-auditors is limited. These situations seem to be due to regulatory measures (e.g., mandatory external rotation and prohibition of NAS) that prevent PIE-auditors from entering the market. Further measures would risk further limitation. Most auditors do not perceive mandatory joint audit as an effective means to enhance market choice. The majority of our members does not see that a mandatory joint audit would enhance audit quality either. IAASB has issued new/revised standards on quality management, risk assessment and procedures for accounting estimates. Projects on audit evidence are ongoing. Additional action by the EC is not required in this regard. Supervision of audit: The efficiency of supervision could be improved by a harmonized approach to minor violations of professional duties that do not threaten professional independence. Root cause analyses of inspection findings would enhance the value of supervision. Supervision of reporting: Increased powers for national authorities could be appropriate in principle, however resources must be used economically (no double audits by auditors and supervisors). More transparency of enforcement activities is generally welcome. However, counter-opinions of the parties concerned need to be made transparent as well. We do not see a need to further strengthen the role of ESMA in the enforcement of audit or reporting.
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Response to EU Standard for Green Bond

27 Sept 2021

The IDW supports the Proposal for a Regulation of the European Parliament and of the Council on European green bonds. Our attached letter discusses the following: Our Support: The IDW welcomes the Proposal as an important part of the European Commission’s broader agenda on sustainable finance, which we fully support. The Proposal can be seen as a positive development, adding a high degree of transparency, legal certainty and comparison to European green bonds. The Commission’s recognition of the imperative for reducing the threat of greenwashing in the EU Green bond market by prescribing involvement of an external reviewer and establishing a system for registering and supervising external reviewers is a key aspect to ensure the success of European green bonds on the global stage. We fully support the Proposal addressing the measures needed to ensure the quality of work performed by external reviewers, whereby the European Securities and Markets Authority (ESMA) is to play a key role in establishing criteria for assessing the eligibility of external reviewers seeking registration including their qualifications, experience, record keeping, transparency, and conflict of interest management as well as in supervision of their compliance in respect of such requirements. Members of the auditing and assurance profession are already subject to a range of requirements aimed at ensuring the quality of their work and in many instances to external supervision, especially in relation to the performance of statutory audits. We suggest that ESMA might usefully draw on this experience in developing the various draft regulatory technical standards foreseen in the Proposal. The IDW would be pleased to assist further in this regard, if required. Our Concerns: We would urge the Commission to further consider the following issues in finalizing the Regulation. 1. The Proposal’s lack of clarification and consistency of reviewers’ work efforts underlying reviewers’ reports may potentially undermine investor confidence in European green bonds. We suggest that requiring external reviewers to confirm in their report their compliance with (and to clearly identify) the specific professional standard pursuant to which they have performed their review would be adequate in providing such clarity and enabling readers to make useful comparisons. 2. The proposed required statement in the reviewer’ report : “The independent opinion of the external review is to be relied upon only to a limited degree.” for both pre-issuance and post-issuance reviews is, at best, unclear (is it intended to imply that the external reviewer has obtained only limited assurance as opposed to the higher level of assurance that the reviewer could have been required to obtain (i.e., reasonable assurance)?). At worst, it could be read as implying that a reviewer’s report is of little value to investors in European green bonds, although we presume that this is not the intention! we suggest clarification be given. 3. The timing of the publication of pre-issuance reviews and post-issuance reviews and is unclear. We suggest phraseology included in Article 30 such as: “within a reasonable period of time” (para. 2), “without delay following the assessment of the allocation reports by the external reviewer” (para. 3) as well as “without delay” (para. 5) be clearer in governing when reports or information are to be made available to the public. IDW Knowledge Paper: In March 2021, the IDW published a knowledge paper on green bonds. An English language version can be assessed: https://www.idw.de/blob/131468/484608a988f845ac66701971bd85a96d/down-knowledgepaper-greenbonds-englisch-data.pdf
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

The IDW supports the Proposal for a CSRD. Our attached letter discusses the following: A globally accepted basis for sustainability reporting will be essential to sustainable growth in Europe. EFRAG should examine which aspects of sustainability reporting shall be addressed at the global level. Implementation deadlines will pose significant challenges to all parties affected. Companies must be given sufficient time to implement new IT systems and internal controls to collect reliable sustainability-related information. Without this timely reporting and external assurance may be unfeasible. Placement of sustainability reporting in the management report helps counter unhelpful "fragmentation" of company-related reporting. Embedding sustainability within reporting entities’ systems of corporate governance is key to the success of sustainability reporting. Reasonable assurance must be the EU Commission’s goal. Earlier adoption of reasonable assurance as a Member State option should be envisaged, esp. for entities already reporting NFI. The underlying subject matter of an assurance engagement must be clarified, so that stakeholders have reasonable expectations, and their needs are addressed where possible. Several issues need to be considered in determining the underlying subject matter of assurance engagements of sustainability reporting. A recent publication by IFAC provides insights into the current sustainability assurance practice in four of the larger EU Member States, indicating that such engagements are performed largely by audit firms or affiliated firms and that ISAE 3000 is most commonly applied, in this context. There are several issues to be borne in mind concerning the provision of assurance services by another independent assurance services provider, in particular requiring the statutory auditor obtain assurance on corporate sustainability reporting brings synergies that benefit both audit and assurance engagement quality. ISAE 3000 (Revised) Assurance Engagements other than Audits or Reviews of Historical Financial Information is generally recognized as the standard applied worldwide to sustainability reporting for both limited and reasonable assurance engagements. The EU Commission should restrict its own role to determining the underlying subject matter for assurance engagements on sustainability reporting, rather than the “mechanics” of assurance procedures. Because information cannot be prepared or audited/assured in XHTML or iXBRL, since these are reproduction formats whose presentation varies with the software and devices used, the final changes to the Directives for ESEF should not refer to the financial statements and sustainability or other reports of the companies concerned having to be prepared in XHTML format, but instead recognise conversion to XHTML is solely for the purpose of publication. Auditor reporting responsibilities that involve both stating whether the auditor has identified material misstatements in the management report and include an opinion on the sustainability reporting relate to reasonable assurance engagements and would demand further clarification for a limited assurance engagement. If supply chain information were part of sustainability reporting, further issues must be considered. For example, entities may not be able to gain access to information from the supply chain outside of the corporate group to comply with EU CSR requirements, or to control the quality of information received from outside the corporate group. This will have an impact on assurance on CSR as part of the financial statement audit.
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Response to Digital Operational Resilience of Financial Services (DORFS) Act

19 Jan 2021

Please find our Feedback in the attached letter.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Vanessa Mock (Cabinet of Executive Vice-President Valdis Dombrovskis)

23 Jan 2020 · Audit

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

22 Apr 2016 · Country-by-country reporting and IFRS9

Meeting with Jonathan Hill (Commissioner)

21 Sept 2015 · Overview on EU Accounting & Audit