Focus Relief Package 2026

The Federal Government has adopted additional measures to streamline and facilitate the environmental, social and human rights due diligence process (ESHR due diligence) conducted under the Investment Guarantee Scheme of the Federal Republic of Germany. These measures will enter into force on 1 August 2026 and are intended to reduce the administrative burden on German companies. The following changes have been approved:

Streamlined process through an Initial Scoping Call: The ESHR due diligence process will follow a new, more dialogue-oriented approach. At the core of this procedural adjustment is an initial scoping call with the applicant’s designated sustainability representatives, which replaces the standardized ESHR questionnaire previously used as the standard procedure. At an early stage of the application process, project-specific risks and relevant sustainability issues will be identified through dialogue, enabling the scope and depth of the subsequent assessment to be tailored more effectively to the characteristics and risk profile of the project. The outcomes of the discussion will be documented in a written meeting record, which will be subject to confirmation by the applicant and will constitute a key element of the ESHR due diligence process going forward.

Simplified ESHR Due Diligence and introduction of a new category K for small-scale projects: To further reduce the administrative burden, particularly for small and medium-sized enterprises (SMEs), a simplified ESHR due diligence procedure will be introduced for investment projects seeking capital cover of up to EUR 2.5 million*. Instead of a comprehensive assessment against the IFC Performance Standards, the review will initially be limited to a focused “red flag” analysis, drawing on internet-based research, web-based ESG screening tools and the findings of the initial scoping call. Where no material environmental, social or human rights risks are identified, the assessment will be concluded at that stage. If relevant concerns or anomalies are detected, a more detailed review of the respective issues will be undertaken. This ensures that the risk-based approach of the ESHR due diligence is maintained, whilst smaller projects in particular benefit from a more streamlined and practical procedure.

* In determining the applicable threshold, the total amount of the cover for capital requested for a project is considered. This includes the combined value of multiple applications submitted for a single project by the same company or corporate group, such as investment-like loans and loans, or several capital increases made over time.