Sustainability Officer: Role and Responsibilities

What are sustainability officers?

Sustainability officers are the individuals designated within a company to be responsible for climate and ESG issues. They implement the sustainability strategy, oversee data collection and reporting, and ensure compliance with regulatory and customer requirements. The title is neither protected nor legally defined in Germany; the company itself determines the scope of the role and the officer’s authority.

Common synonyms include sustainability manager, CSR manager, and ESG manager. In practice, these terms refer to the same position, not to different job profiles.

Areas of Responsibility

The scope of these responsibilities varies greatly depending on the size of the company. In a medium-sized company with 300 employees, this role is typically filled by one person working half-time; in large corporations, it is divided among a team. There are five recurring categories of tasks:

• Strategy and Goals: Develop a sustainability and climate strategy, set reduction targets, and, if necessary, have them validated by the SBTi.
• Data Collection and Reporting: Develop a greenhouse gas inventory in accordance with the GHG Protocol; consolidate data sources from procurement, facility management, and finance; and maintain emission factors.
• Reporting: Sustainability Report, CDP Questionnaire, EcoVadis Scorecard, Customer Surveys.
• Regulatory Framework: Monitor the CSRD, EU Taxonomy, supply chain due diligence requirements, and industry-specific guidelines, and determine the need for internal action.
• Implementation and Capacity Building: Initiate reduction measures, train departments, and establish responsibilities outside the sustainability department.

Distinction from related roles

This role is often confused with that of safety officers required by law. The difference is not merely theoretical: it determines whether an appointment is legally required or a business decision.

Sustainability management does not replace specialized functions. It coordinates them—so that environmental officers, energy management, and compliance do not maintain three separate sets of data.

Regulatory Context: As of August 2026

The widespread assumption that the CSRD requires virtually every large company to report will no longer be true as of February 2026. Amending Directive (EU) 2026/470 was published in the Official Journal of the European Union on February 26, 2026, and entered into force in mid-March 2026; Member States must implement it by March 19, 2027. The scope of the CSRD has been significantly narrowed, and companies subject to reporting requirements for the first time will report for the 2027 fiscal year. In Germany, the CSRD Implementation Act had not been finalized as of August 2026.

What the role entails in practice

The Omnibus Act has not reduced the need for this function, but rather shifted the trigger. Those who have fallen outside the scope of the CSRD continue to face the same data requirements—only now they come from the supply chain rather than the Official Gazette: through customer questionnaires, EcoVadis assessments, and CDP requests. This is our assessment based on ongoing client engagements; it is not supported by documented market statistics.

The most common design flaw when filling this role for the first time is the way it’s structured. If the position is placed under Marketing or Quality Management, it lacks access to purchasing and energy data, and the first carbon footprint assessment fails not because of a lack of expertise, but because of difficulties in obtaining the necessary data. Linking the role to senior management or Finance solves this problem, but it requires attention at the executive level—those unwilling to provide that attention should not fill the role in the first place.

Internal or external hiring

For companies with fewer than about 500 employees, it rarely makes financial sense to maintain a dedicated full-time position. It is difficult to develop in-depth expertise in accounting, reporting, and regulatory matters with a part-time position, and such knowledge becomes outdated between two reporting cycles. The alternative is to outsource the work: Five Glaciers Consulting takes on the role of interim sustainability management with a defined number of hours and simultaneously builds up internal capabilities.

The argument against this is that external parties do not have informal access to the departments. Without an internal point of contact with the necessary authority, even a good external hire will get bogged down in the data collection process. The combination works; outsourcing alone rarely does.

Sources

1. Directive (EU) 2026/470 of the European Parliament and of the Council, Official Journal of the European Union, February 26, 2026.
2. German Accounting Standards Committee (DRSC): CSRD Amendment Directive Published in the Official Journal of the EU, 2026 (effective date, implementation deadline: March 19, 2027).
3. Baker Tilly: CSRD – EU Publishes Omnibus Amendment Directive in the Official Journal, 2026 (Effective for the 2027 fiscal year; status of German implementation).

Author: Kevin Möller · Last updated: August 2026