What is the CSRD and How Has Ireland Implemented It?
The CSRD entered into force at EU level in January 2023. Ireland transposed it through the European Union (Corporate Sustainability Reporting) Regulations 2024. The regulations require in-scope companies to disclose Environmental, Social, Governance (ESG) and human rights information under the European Sustainability Reporting Standards (ESRS), supporting the EU’s sustainable finance objectives under the European Green Deal.
In July 2025, Ireland gave effect to the EU “Stop the Clock” Directive. This deferred reporting obligations for the second wave (large EU entities) and third wave (SMEs) by two years until 2027, allowing time for the Omnibus negotiations to conclude.
How Has the EU Omnibus Directive Changed CSRD Reporting Requirements?
The Omnibus 1 Directive, was published in the Official Journal on 26 February 2026 and took effect on 18 March 2026. It simplifies the CSRD, revises its scope and sets new timelines. The key points are:
- Revised scope. Only EU entities with more than 1,000 employees and net turnover above €450 million fall within mandatory reporting, applying to financial years starting on or after 1 January 2027. Non-EU entities are in scope from financial years starting on or after 1 January 2028;
- Transposition deadline. Member states must transpose the CSRD-related amendments by 19 March 2027, so Ireland will need to amend its 2024 regulations; and
- Wider changes. The Omnibus also amends related legislation, including the Corporate Sustainability Due Diligence Directive (CSDDD), concentrating obligations on the largest companies.
Who Needs to Comply with CSRD in Ireland and When Must They Report?
- First-wave reporters. Large public-interest entities previously subject to the Non-Financial Reporting Directive have already filed their first CSRD reports for FY2024. The Omnibus lets member states exempt those falling below the new thresholds from reporting for FY2025 and FY2026, but only if Ireland exercises that option in its transposing regulations. Until it does, existing obligations stand;
- Newly in-scope companies. Companies meeting the revised thresholds that have not yet reported will begin with FY2027. Given the volume of data involved, early preparation is sensible, with many advisers suggesting a lead time of 18 to 24 months;
- Format. Sustainability statements form part of the annual management report, must be digitally tagged, and are intended to be accessible through the European Single Access Point (ESAP); and
- Enforcement. Enforcement is a matter for the competent authorities under Irish law. Companies should assume that non-compliance carries meaningful regulatory consequences.
European Sustainability Reporting Standards (ESRS): What Do Companies Need to Disclose?
The ESRS set out what companies must disclose. There are twelve standards in total: two cross-cutting standards (ESRS 1 and ESRS 2) and ten topical standards across three areas:
- Environment (E1 to E5): climate change, pollution, water and marine resources, biodiversity, and resource use and the circular economy;
- Social (S1 to S4): own workforce, workers in the value chain, affected communities and consumers; and
- Governance (G1): business conduct, including ethics and anti-corruption.
The standards apply Double Materiality. Companies must report both how sustainability matters affect the business (financial materiality) and how the business affects people and the environment (impact materiality). Double materiality is retained, but the ESRS are being simplified, with a sharp reduction in mandatory datapoints, so companies should track the final text before committing to detailed data collection.
What Does the CSRD Omnibus Directive Mean for Irish Businesses?
- Companies exceeding both Omnibus thresholds should prepare for FY2027 reporting;
- Non-EU groups with significant EU operations may be in scope from FY2028;
- Preparation should start now, focusing on durable foundations such as materiality assessment, data governance and digital reporting readiness, rather than on datapoints likely to be removed; and
- First-wave companies below the new thresholds should watch the Irish transposition closely to see whether an exemption is granted.
Conclusion
The direction is clear even if the detail is not. Ireland has a working CSRD framework, but the EU has cut its reach to the largest companies and is trimming the standards. The next milestones are Ireland’s transposition of the Omnibus and the final simplified ESRS, and those will determine how much of the earlier preparation remains relevant.
CSRD Ireland: Key Regulatory Changes and Developments to Watch in 2027
Four developments will shape the next twelve months:
- Irish transposition of Omnibus 1: due by March 2027, and in particular whether Ireland exempts sub-threshold Wave 1 companies;
- The simplified ESRS: whose final datapoint count and structure will define the real compliance burden from FY 2027;
- Assurance standards: including how the EU’s approach to limited assurance develops and how IAASA’s standard adapts; and
- Voluntary reporting: as companies outside scope decide whether to use the VSME standard in response to lender, investor and customer requests.
RBK’s ESG, Sustainability and CSRD Advisory Team
Here in RBK, Partners Michelle O’Donoghue and Charlene McCrossan as well as Manager Gareth Fitzpatrick have recently completed diplomas in Sustainability Reporting and Assurance. They, in conjunction with Partner Colm O’Grady, lead up RBK’s ESG, Sustainability and CSRD working group.
If you have any queries, or need assistance, please contact [email protected]
