CSRD: Recent developments impacting Irish companies

In this briefing, we provide an overview of some recent CSRD-related developments which will be of interest to Irish companies.

Publication of the European Union (Corporate Sustainability Reporting) Regulations 2025

On 11 July 2025, the European Union (Corporate Sustainability Reporting) Regulations 2025 (Irish CSRD Amending Regulations) were published.

The Irish CSRD Amending Regulations introduce a number of changes to the existing CSRD framework applicable to Irish companies, an overview of which is outlined below.

Transposition of the “Stop the Clock” Directive into Irish law

The Irish CSRD Amending Regulations delay the application of CSRD to Irish companies which constitute “large companies” under Irish law until 2028 (in respect of the 2027 financial year). They also delay the application of CSRD Irish listed SMEs until 2029 (in respect of the 2028 financial year). 

This is to allow the co-legislators adequate time to consider and reach agreement on the European Commission’s sustainability omnibus proposal under which significant reform of the CSRD has been proposed (Sustainability Omnibus Proposal)[1]. 

Clarification on the scope of CSRD reporting obligations

The Irish CSRD Amending Regulations clarify that entities which constitute “ineligible entities” under Irish company law only fall within the scope of the CSRD reporting obligations if they meet applicable size criteria[2].

This means that, aligned with the CSRD itself, entities regulated by the Central Bank of Ireland such as Irish fund management companies and Irish investment firms will not be subject to CSRD reporting obligations unless they meet the applicable size criteria.

The Irish CSRD Amending Regulations also clarify that Irish subsidiaries with EU parents may avail of the subsidiary exemption.

Clarification on the definition of “net turnover” under the Irish CSRD framework

The definition of “net turnover” for the purposes of determining whether or not a company falls within the scope of the CSRD has also been aligned with the definition used under CSRD. 

This clarification is of particular importance to Irish-domiciled special purpose vehicles (SPVs) as under the revised rules, gross revenue derived from the making or holding of investments should not be included when calculating net turnover for the purposes of determining whether or not an SPV falls within the scope of CSRD reporting obligations. 

Proposal to delay the application of certain ESRS requirements applicable to companies already reporting under CSRD

As readers will be aware, certain Irish companies are already reporting under the CSRD framework by virtue of falling within the first wave of reporting obligations (Wave 1 Companies)[3].

On 11 July 2025, the European Commission announced that it has adopted targeted “quick-fix” amendments to the first set of the ESRS[4] issued under the CSRD (Proposal).

Under the Proposal, Wave 1 Companies can omit information on, amongst other things, the anticipated financial effects of certain sustainability-related risks when reporting on financial years 2025 and 2026. This means that such companies will not have to report additional information when compared to financial year 2024. 

The Proposal has been submitted to the European Parliament and the Council of the EU for their consideration. If no objections are raised by either institution , the relevant legislation  will be published in the Official Journal of the EU on expiry of the scrutiny period and will enter into force on the third day following publication.

Separately, the European Commission is working on a broader revision of the ESRS in order to substantially reduce the number of data requirements, improving consistency with other pieces of legislation and clarifying provisions deemed unclear. It has indicated that this review should be completed by the “2027 financial year”.

Council of the EU adopts its negotiating mandate on the Sustainability Omnibus Proposal

On 23 June 2025, the Council of the EU announced that EU Member State representatives had reached agreement on its negotiating mandate on the Sustainability Omnibus Proposal published by the European Commission in February 2025.

The Council of the EU has suggested the following changes to the CSRD proposals put forward by the European Commission:

• The net turnover threshold for triggering the scope of the CSRD for companies should be increased from the €50 million proposed by the European Commission to €450 million.

• The removal of listed SMEs from the scope of the CSRD.

• The introduction of a review clause to consider the extension of the scope of CSRD to ensure adequate availability of corporate sustainability information.

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Footnotes:
[1] For a detailed overview of the European Commission’s omnibus proposal, please refer to our briefing on the topic.
[2] In order for a “large company” within the meaning of the Companies Act 2014 to be brought within the scope of the CSRD reporting obligation, the company must meet two of the following size criteria: (i) balance sheet of greater than €25 million, (ii) turnover of greater than €50 million and (iii) more than 250 employees.
[3] This includes Irish companies whose shares are listed on a main EU market, credit institutions and insurance undertakings in each case which have more than 500 employees.
[4] European Sustainability Reporting Standards (or ESRS) are the standards which must be reported against under the CSRD framework.