It can be expected that henceforth members of the supervisory board will have to be more explicit than in the past when writing their supervisory board reports. The District Court in Munich pointed out that the supervisory board is not allowed to simply say in its report to the shareholders that it has monitored the managing directors by means of management reports and regular joint meetings. Instead, it must report specifically about each individual audit measure taken by the supervisory board. The District Court in Berlin refused to acknowledge the widely used language stating that the supervisory board had approvingly taken notice of the CPA’s audit result as well as the year end report, management report und proposal of the management for the profit distribution and that no objections were raised. According to the District Court in Berlin, this wording lacks perceptibility of the supervisory board’s own audit results. There seems to be a development towards a tougher audit and control intensity by the supervisory board which is in line with international trends following the Enron case, such as the Sarbanes-Oxley Act in the U.S. and similar legislation in other countries. Especially in light of the comparably low remuneration of German members of the supervisory board it can be expected that the growing responsibility and the therefore higher liability risk will have its effects in the medium and long term. One possible effect is that qualified members of supervisory boards will ask for higher compensation, another is that premiums for D&O insurance will go up considerably in light of the increased risk profile.