We estimate there are about 250 Irish companies who will be in scope for CSRD reporting for their 2027 financial year*.
From what we’re seeing in the marketplace, a lot of companies downed tools in this area after the changes at EU level. A number appear to have paused work entirely after postponement, but the reality is many will still have a significant amount to do and the timeline is tighter than people think.
We anticipate that some firms will face significant challenges in establishing the necessary governance frameworks, systems, and ESG data collection processes. They also face real compliance, enforcement and reputational risks if they leave preparations too late.
There is limited time for companies to ensure they are fully prepared and organized.
The first thing they need to do is assess whether they are actually in scope or not, which is not a straightforward exercise. The likelihood of a further extension is limited given that an extension was already granted last year.
They then need to put in place a system to gather the required data on your sustainability performance, again this is not straightforward.
These two things are the key factors as to why firms may face a scramble.
FAQ
1. What are the CSRD deadlines?
The CSRD is being rolled out in phases, but recent EU reforms (the “Omnibus” package adopted in February 2026) have delayed and narrowed many requirements.
Current timeline:
- 2025 (reports covering FY2024)
Large public-interest entities already subject to NFRD (e.g. listed companies, banks, insurers with 500+ employees) began reporting. - 2028 (reports covering FY2027)
Other large companies still in scope under revised thresholds will report for the first time following a two-year delay introduced by the EU. - 2029 (reports covering FY2028)
Non-EU companies with significant EU operations enter scope.
2. How do companies know if they are in scope?
The scope has changed significantly in 2026.
Under the latest rules, an EU company is in scope if it meets both of the following criteria:
- More than 1,000 employees, and
- More than €450 million in net turnover
For non-EU companies, the rules generally apply where:
- EU-group turnover exceeds €450m either individually or on a consolidated basis, for each of the last 2 consecutive financial years and
- the EU branch’s turnover exceeds €200m.
3. What does “voluntary compliance” mean under CSRD?
Even if a company is no longer legally required to report under CSRD, it may still choose to report voluntarily.
This typically involves:
- Reporting in line with ESRS (European Sustainability Reporting Standards), like companies falling under CSRD or
- Using a simplified voluntary framework such as the VSME (Voluntary Sustainability Reporting Standard for SMEs) developed by the EU.
Why companies do this:
- To meet investor or lender expectations
- To satisfy supply chain requirements from larger in-scope companies
- To prepare for future regulatory expansion or threshold changes
- To remain competitive in ESG-focused markets
There are numerous technical nuances within the regulations. Please speak to our team directly for a more detailed technical review.
*Note: This is financial years beginning 1 Jan 2027 or after.
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