Assurance report of the independent German public auditor on a limited assurance engagement in relation to the Group sustainability declaration
To Deutsche Lufthansa Aktiengesellschaft, Cologne
We have conducted a limited assurance engagement on the Group sustainability declaration, included in the “Combined non-financial declaration” section of the combined management report, of Deutsche Lufthansa Aktiengesellschaft for the fiscal year from 1 January 2024 to 31 December 2024. The Group sustainability declaration was prepared to fulfill the requirements of Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 (Corporate Sustainability Reporting Directive, CSRD) and Art. 8 of Regulation (EU) 2020/852 as well as Secs. 289b to 289e and Secs. 315b and 315c HGB [“Handelsgesetzbuch”: German Commercial Code] for a Group non-financial declaration which is combined with the parent company’s non-financial declaration.
Based on the procedures performed and the evidence obtained, nothing has come to our attention that causes us to believe that the accompanying Group sustainability declaration is not prepared, in all material respects, in accordance with the requirements of the CSRD and Art. 8 of Regulation (EU) 2020/852, Secs. 289b to 289e and Secs. 315b and 315c HGB for a Group non-financial declaration which is combined with the parent company’s non-financial declaration and the supplementary criteria presented by the executive directors of the Company. This assurance conclusion includes that nothing has come to our attention that causes us to believe that:
- The accompanying Group sustainability declaration does not comply, in all material respects, with the European Sustainability Reporting Standards (ESRS), including that the process carried out by the Company to identify information to be included in the Group sustainability declaration (the materiality assessment) is not, in all material respects, in accordance with the description set out in the “Combined non-financial declaration” section of the Group sustainability declaration, or
- The disclosures in the Group sustainability declaration do not comply, in all material respects, with Art. 8 of Regulation (EU) 2020/852.
Basis for the assurance conclusion
We conducted our assurance engagement in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised): Assurance Engagements Other Than Audits or Reviews of Historical Financial Information issued by the International Auditing and Assurance Standards Board (IAASB).
The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed.
Our responsibilities under ISAE 3000 (Revised) are further described in the section “German public auditor’s responsibilities for the assurance engagement on the Group sustainability declaration.”
We are independent of the Company in accordance with the requirements of European law and German commercial and professional law, and we have fulfilled our other German professional responsibilities in accordance with these requirements. Our audit firm has applied the requirements for a system of quality control as set forth in the IDW Quality Management Standard issued by the Institut der Wirtschaftsprüfer [Institute of Public Auditors in Germany] (IDW): Requirements for Quality Management in the Audit Firm (IDW QMS 1 (09.2022)). We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our assurance conclusion.
Responsibilities of the executive directors and the Supervisory Board for the Group sustainability declaration
The executive directors are responsible for the preparation of the Group sustainability declaration in accordance with the requirements of the CSRD and the applicable German legal and other European requirements as well as with the supplementary criteria presented by the executive directors of the Company and for designing, implementing and maintaining such internal control that they have considered necessary to enable the preparation of a Group sustainability declaration in accordance with these requirements that is free from material misstatement, whether due to fraud (i.e., fraudulent sustainability reporting in the Group sustainability declaration) or error.
This responsibility of the executive directors includes establishing and maintaining the materiality assessment process, selecting and applying appropriate reporting policies for preparing the Group sustainability declaration, as well as making assumptions and estimates and ascertaining forward-looking information for individual sustainability-related disclosures.
The Supervisory Board is responsible for overseeing the process for the preparation of the Group sustainability declaration.
Inherent limitations in preparing the Group sustainability declaration
The CSRD and the applicable German legal and other European requirements contain wording and terms that are subject to considerable interpretation uncertainties and for which no authoritative, comprehensive interpretations have yet been published. As such wording and terms may be interpreted differently by regulators or courts, the legality of measurements or evaluations of sustainability matters based on these interpretations is uncertain.
These inherent limitations also affect the assurance engagement on the Group sustainability declaration.
German public auditor’s responsibilities for the assurance engagement on the Group sustainability declaration
Our objective is to express a limited assurance conclusion, based on the assurance engagement we have conducted, on whether any matters have come to our attention that cause us to believe that the Group sustainability declaration has not been prepared, in all material respects, in accordance with the CSRD, the applicable German legal and other European requirements and the supplementary criteria presented by the Company’s executive directors, and to issue an assurance report that includes our assurance conclusion on the Group sustainability declaration.
As part of a limited assurance engagement in accordance with ISAE 3000 (Revised), we exercise professional judgment and maintain professional skepticism. We also:
- Obtain an understanding of the process used to prepare the Group sustainability declaration, including the materiality assessment process carried out by the Company to identify the disclosures to be reported in the Group sustainability declaration.
- Identify disclosures where a material misstatement due to fraud or error is likely to arise, design and perform procedures to address these disclosures and obtain limited assurance to support the assurance conclusion. The risk of not detecting a material misstatement resulting from fraud is higher than the risk of not detecting a material misstatement resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. In addition, the risk of not detecting a material misstatement in information obtained from sources not within the Company’s control (value chain information) is ordinarily higher than the risk of not detecting a material misstatement in information obtained from sources within the Company’s control, as both the Company’s executive directors and we as practitioners are ordinarily subject to restrictions on direct access to the sources of the value chain information.
- Consider the forward-looking information, including the appropriateness of the underlying assumptions. There is a substantial unavoidable risk that future events will differ materially from the forward-looking information.
Summary of the procedures performed by the German public auditor
A limited assurance engagement involves the performance of procedures to obtain evidence about the sustainability information. The nature, timing and extent of the selected procedures are subject to our professional judgment.
In performing our limited assurance engagement, we:
- Gained an understanding of the structure of the sustainability organization and stakeholder engagement
- Evaluated the suitability of the criteria as a whole presented by the executive directors in the Group sustainability declaration.
- Inquired of the executive directors and relevant employees involved in the preparation of the Group sustainability declaration about the preparation process, including the materiality assessment process carried out by the Company to identify the disclosures to be reported in the Group sustainability declaration, and about the internal controls relating to this process.
- Evaluated the reporting policies used by the executive directors to prepare the Group sustainability declaration.
- Evaluated the reasonableness of the estimates and related information provided by the executive directors. If, in accordance with the ESRS, the executive directors estimate the value chain information to be reported for a case in which the executive directors are unable to obtain the information from the value chain despite making reasonable efforts, our assurance engagement is limited to evaluating whether the executive directors have undertaken these estimates in accordance with the ESRS and assessing the reasonableness of these estimates, but does not include identifying information in the value chain that the executive directors were unable to obtain.
- Performed analytical procedures and made inquiries in relation to selected information in the Group sustainability declaration.
- Considered the presentation of the information in the Group sustainability declaration.
- Considered the process for identifying taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclosures in the Group sustainability declaration.
- Considered the existence of carbon offset certificates, but not their effectiveness.
Restriction of use
We draw attention to the fact that the assurance engagement was conducted for the Company’s purposes and that the assurance report is intended solely to inform the Company about the result of the assurance engagement. As a result, it may not be suitable for another purpose than the aforementioned. Accordingly, the assurance report is not intended to be used by third parties for making (financial) decisions based on it. Our responsibility is to the Company alone. We do not accept any responsibility to third parties. Our assurance conclusion is not modified in this respect.
General Engagement Terms and Liability
The “General Engagement Terms for Wirtschaftsprüferinnen, Wirtschaftsprüfer and Wirtschaftsprüfungsgesellschaften [German Public Auditors and Public Audit Firms]” dated 1 January 2024, which are attached to this report, are applicable to this engagement and also govern our relations with third parties in the context of this engagement (ey-idw-aab-de-2024.pdf).
In addition, please refer to the liability provisions contained there in no. 9 and to the exclusion of liability towards third parties. We accept no responsibility, liability or other obligations towards third parties unless we have concluded a written agreement to the contrary with the respective third party or liability cannot effectively be precluded.
We make express reference to the fact that we will not update the assurance report to reflect events or circumstances arising after it was issued, unless required to do so by law. It is the sole responsibility of anyone taking note of the summarized result of our work contained in this report to decide whether and in what way this result is useful or suitable for their purposes and to supplement, verify or update it by means of their own review procedures.
Düsseldorf, 4 March 2025
EY GmbH & Co. KG
Wirtschaftsprüfungsgesellschaft
Dr. Alexander Eisele Christopher Hintze
Wirtschaftsprüfer Wirtschaftsprüfer
[German Public Auditor] [German Public Auditor]