About this non-financial declaration

Deutsche Lufthansa AG prepares and publishes the combined non-financial declaration in accordance with Sections 315b and 315c German Commercial Code (HGB) in conjunction with Sections 289c to 289e HGB and Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 on the establishment of a framework to facilitate sustainable investment and Art. 8 of Delegated Regulation (EU) 2020/852 (EU Taxonomy Regulation).

CSRD and ESRS are the new European framework for sustainability reporting

The Corporate Sustainability Reporting Directive (CSRD) represents a significant expansion of existing EU directives on non-financial reporting. It took effect at the EU level on 5 January 2023 and must be transposed into national law by the EU member states. Among other things, the intention is to oblige large, capital market-orientated undertakings in the EU to report in their sustainability reporting on all the impacts of their business activities on sustainability matters and on how sustainability matters affect the undertaking’s development, performance and economic situation. Reporting is based on the European Sustainability Reporting Standards (ESRS), which apply directly in all EU member states as a delegated regulation. The national CSRD Transposition Act (CSRD-UmSG) is currently still in the parliamentary process. The German federal government is aiming for a 1:1 implementation of the updated CSRD draft as well as of the supplementary “Stop-the-Clock” Directive (EU) 2025/794, which postpones certain reporting obligations. The law had not yet come into effect in Germany as of 31 December 2025, so the existing legal requirements of the current reporting framework continue to apply for the Lufthansa Group.

The combined non-financial declaration of Deutsche Lufthansa AG has once again been prepared fully in line with the ESRS

The Lufthansa Group is reporting for the second time on a voluntary basis in accordance with the requirements of the CSRD and the ESRS. The transition from the internationally recognised GRI standard to the European framework was already completed in the 2024 financial year. For the 2025 financial year, reporting is likewise based on the ESRS and, in part, on the application of the delegated act amending Delegated Regulation (EU) 2023/2772 (“Quick Fix”). The aim is to prepare early for the national implementation of the CSRD into German law and to ensure structured and comparable sustainability reporting.

Structure and methodology of the combined non-financial declaration

As in the previous year, Deutsche Lufthansa AG publishes a non-financial declaration at Company level and a non-financial Group declaration together as a combined non-financial declaration. The Lufthansa Group’s combined non-financial declaration is an integral part of the management report. In line with the ESRS requirements, the material topics were selected on the basis of their impacts, relevance and assessment of their potential financial impacts. Material matters and facts relating to environmental concerns, customer concerns, employee concerns, social concerns, business ethics and compliance, including anti-corruption and bribery as well as respect for human rights and sustainability in the supply chain, are organised by subject matter and divided into four sections in accordance with ESRS: General Disclosures, Environment, Social and Governance.

The individual sections of the combined non-financial declaration are also based on the structure of ESRS standards. All ESRS requirements include direct references to the relevant sections and paragraphs of ESRS standards.

The first section gives an overview of the basic procedure for sustainability reporting, including a presentation of the value chain, engagement with stakeholders and the materiality assessment and methodology applied. Disclosures about the Lufthansa Group strategy, its business model and corporate governance from the overarching standard ESRS 2 are also included in the general disclosures.

The Environment section provides comprehensive information about environmental actions and takes into account the requirements of the reporting obligations within the meaning of the applicable EU Taxonomy regulations. This section also covers climate change, pollution, resource use and circular economy and the EU Taxonomy. In addition to the ESRS and EU Taxonomy requirements, the Lufthansa Group also provides further Company-specific information on the topics of noise pollution and the replacement of disposable plastic and aluminium articles.

The Social section includes disclosures on the Lufthansa Group’s own workforce, the working conditions within the value chain and actions affecting customers.

The Governance section is dedicated to actions relating to responsible corporate governance. They include the compliance and risk management systems, as well as actions to promote ethical business conduct.

Reconciliation of sustainability matters between HGB requirements and the ESRS framework and contextualisation of the matters

In addition to the statutory audit of the consolidated financial statements and the Group management report, which is combined with the management report, the Supervisory Board of Deutsche Lufthansa AG has voluntarily engaged an external auditing firm to carry out a limited assurance review of the combined non-financial declaration.

Most significant non-financial performance indicators for Deutsche Lufthansa AG

Deutsche Lufthansa AG is the parent of the Lufthansa Group and is therefore obliged to make additional non-financial disclosures. This particularly concerns reporting on the most significant non-financial performance indicators, which also became mandatory for Deutsche Lufthansa AG as the parent when the German CSR Directive Transposition Act came into effect in 2017.

The integrated presentation in the management report was chosen for the non-financial declaration to be made in the reporting year in accordance with Section 289b to e HGB. For the above statements in the management report, all disclosures, rules, processes and performance indicators always apply to the Lufthansa Group, including Deutsche Lufthansa AG. No additional matters within the meaning of the German CSR Directive Transposition Act were identified that only apply to Deutsche Lufthansa AG.