Page Contents
Related areas
Key contacts
It has a been a busy few months for updates on sustainability reporting and due diligence requirements. A number of updates have been published since our last sustainability reporting update. In this article, we have set out a brief overview of some of the key developments that companies should be aware of.
Irish sustainability reporting updates
1. Amendment to CSRD FAQs
In early 2025, a clarification was made to the Corporate Sustainability Reporting Directive (CSRD) FAQs prepared by the Department of Enterprise, Trade and Employment (DETE). This acknowledges that the scope of entities subject to sustainability reporting obligation under the Irish legislation implementing CSRD is broader than under CSRD including those that are deemed “large”.
2. DETE to amend Irish CSRD regulations and implement EU’s ‘Stop the Clock’ directive
On 31 March 2025, the Minister for Enterprise, Tourism and Employment welcomed the proposals to simplify the sustainability obligations being placed on businesses under CSRD and the Corporate Sustainability Due Diligence Directive (CSDDD). He announced that the Department will focus on quickly implementing the EU’s ‘Stop the Clock’ proposal, which has since been published as a directive. In addition, he indicated that the existing Irish legislation transposing CSRD will shortly be amended to further clarify and reduce the scope of companies covered.
3. IAASA Launch Public Consultation on Policy Paper on its Corporate Reporting Supervision
On 13 May 2025, the Irish Auditing & Accounting Supervisory Authority (IAASA) launched a public consultation on its policy paper on the publication of information regarding IAASA’s corporate reporting supervision. The IAASA proposes update the policy paper to provide transparency on the results of sustainability reporting examinations as well as financial reporting examinations following the coming into force of CSRD. The consultation is open until 18 July 2025.
EU sustainability reporting updates
1. ESMA consults on proposals to digitalise sustainability and financial disclosures
On 13 December 2024, the European Securities and Markets Authority (ESMA) announced the publication of a Consultation Paper seeking stakeholders’ views on how the European Single Electronic Format (ESEF) can be applied to sustainability reporting. The proposals also aim to ease the burden associated with financial reporting.
ESMA has been considering the feedback it received to this consultation throughout the second quarter of 2025. ESMA expects to publish a final report in the third quarter and to submit the draft technical standards to the European Commission (the Commission) for endorsement.
2. EFRAG releases the voluntary reporting standard for non-listed SMEs
On 17 December 2024, EFRAG announced the delivery of its technical advice on the voluntary reporting standard for non-listed micro-, small-, medium sized undertakings (VSME Standards).
By way of background, the VSME Standards are designed for undertakings that are not mandatorily required to comply with sustainability reporting obligations in accordance with CSRD. Some key features of the VSME Standards include:
3. Omnibus package - Amendments proposed to CSRD, CSDDD, CBAM and Taxonomy consultation
On 26 February 2025, the Commission published its Omnibus package on sustainability, the first of a number of planned omnibus packages aimed at simplifying EU rules and reducing the sustainability reporting burden on EU companies. This package contains proposals to amend the following existing legislation:
In February 2025, we published an article providing a brief overview of the proposed amendments introduced as part of the Omnibus Package. In March 2025, we published two additional articles providing an overview of the amendments proposed to the CSDDD and CBAM Regulation.
4. EFRAG and CDP publish correspondence mapping between CDP question bank and ESRS E1
On 18 March 2025, EFRAG and Carbon Disclosure Project (CDP) published a correspondence mapping between the CDP question bank and the ESRS E1. This resource highlights the high degree of interoperability between ESRS E1 disclosure requirements relating to climate change and the CDP question bank in areas such as transition plans for climate change mitigation, targets related to climate change mitigation, gross Scope 1, 2 and 3 emissions, and internal carbon pricing.
According to both organisations, the new resource will help companies reduce complexity, build reporting efficiency and enhance transparency for stakeholders. ESRS E1 reporters will be better equipped to complete CDP disclosures, while CDP disclosing companies will be well prepared for ESRS E1 reporting requirements.
5. EFRAG mandated to simplify ESRS
On 27 March 2025, the Commission delivered its formal request for technical advice on the revision and simplification of the ESRS to EFRAG. In its mandate, the Commission requested that EFRAG deliver a draft of the revised ESRS to the Commission by 31 October 2025.
6. EFRAG launched public call on ESRS Set 1 revision
On 8 April 2025, the EFRAG launched a public call for input on the ESRS Set 1 revision.
The consultation sought feedback from companies required to report under CSRD as well as all other relevant stakeholders.
7. ‘Stop the Clock’ Directive published in the Official Journal
On 16 April 2025, the ‘Stop the Clock’ Directive was published in the Official Journal.
By way of background, the stop-the-clock directive is part of the European Commission’s broader Omnibus package on sustainability. It postpones:
The Directive entered into force on 17 April 2025. EU member states have until 31 December 2025 to implement the changes into national law.
8. EFRAG delivers work plan for the simplification of ESRS
On 25 April 2025, EFRAG officially submitted its work plan to the Commission outlining the steps it will take to revise and simplify the ESRS.
EFRAG’s work plan sets out the key activities, deliverables, and stakeholder engagement that EFRAG will undertake to meet the October deadline. It includes a public consultation on the exposure drafts which will take place between the end of July and early September.
9. ESMA publishes guidelines on enforcement of sustainability information
On 29 April 2025, ESMA published its Guidelines on Enforcement of Sustainability Information, setting out how national authorities should select, examine and enforce sustainability disclosures under the Transparency Directive. The guidelines aim to align sustainability reporting oversight with financial reporting enforcement. They apply from 1 January 2025 to issuers listed on regulated markets who must publish sustainability information under the Accounting Directive, including those using the ESRS or equivalent standards.
10. Quick fix for phase-in of disclosure requirements for wave 1 entities
On 13 May 2025, during a public hearing in the legal affairs committee of the European Parliament, it was announced that the Commission expects to soon adopt a ‘quick fix’ delegated act to reduce the CSRD reporting obligations for wave 1 companies. The proposal would revise the existing ESRS to at least ensure that companies that had to begin reporting for financial year 2024 do not have to report additional information when reporting for financial years 2025 and 2026.
11. Ombudswoman opens inquiry into Commission’s adoption of Omnibus package
On 22 May 2025, the European Ombudswoman announced that following the submission of complaints, an inquiry was being opened into how the Commission prepared a legislative proposal included in its omnibus package of simplification measures. The inquiry will specifically focus on whether the Commission complied with its own Better Regulation Guidelines by not providing a justification for omitting a public consultation or an impact assessment on the draft legislation, and for not conducting a climate consistency assessment as mandated by the European Climate Law.
12. Commission plans to adopt the VSME Standards as a recommendation
On 3 June 2025, during EFRAG’s Second SME Forum Meeting, it was confirmed that the Commission intends to adopt the VSME Standards as a recommendation in the coming months. Separately, a delegated act dealing with the value chain cap will be published. EFRAG did not provide any further details in respect of this delegated act, simply noting that it was clear that the political intention is to keep it as simple as possible.
EU sustainability due diligence updates
1. Commission launches EUDR Information System
On 6 December 2024, the Commission launched the Deforestation-free Regulation (EUDR) information system where due diligence statements under the EUDR must be submitted.
The information system is a key tool that can be used by operators, traders and their representatives to make electronic due diligence statements, enabling them to be submitted to the relevant authorities to show that their products do not cause deforestation or forest degradation. Statements submitted in the information system are to cover only products that will be made available on the market or exported after the entry into force of the EUDR.
To support users in familiarising themselves with the system, the Commission has also launched a replica training server, which allows users to practice submitting due diligence statements.
A user guide and frequently asked questions about the EUDR Information System are available here.
2. Regulation on prohibition of products made with forced labour published in the Official Journal
On 12 December 2024, Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market was published in the Official Journal.
The Regulation establishes a structured framework relating to a prohibition on placing or making available on the EU market products that are made with forced labour and ensuring that such products aren’t exported.
The Regulation entered into force on 13 December 2024 with EU member states having 3 years to start applying the new rules.
3. Regulation amending the EUDR published in the Official Journal
On 23 December 2024, Regulation (EU) 2024/3234 was published in the Official Journal entering into force on 26 December 2024. The Regulation amends the EUDR as regards provisions relating to its date of application. The obligations stemming from this regulation will be binding from:
4. Commission further simplifies the implementation of the EUDR
On 15 April 2025, the Commission provided further simplifications to facilitate the implementation of the EUDR. In this context, the Commission has published new guidance documents in view of the Regulation’s entry into application at the end of this year.
The updated guidance and Frequently Asked Questions will provide companies, EU member states' authorities and partner countries with additional simplified measures and clarifications on how to demonstrate that their products are deforestation-free.
5. Commission publishes proposal and public consultation on Batteries Regulation
On 21 May 2025, the Commission published a proposal affecting the timeline and scope of the Batteries Regulation (EUBR) (Regulation 2023/1542), aimed at streamlining compliance and providing clarity for economic operators within the batteries sector. The proposal recommends a two-year postponement of the mandatory due diligence obligations for battery raw materials, shifting the application date from August 2025 to August 2027. On 23 May 2025, the European Commission launched a consultation on this proposal, which will remain open until 25 July 2025.
6. Commission publishes country benchmarking to help fight deforestation worldwide
The Commission has published the first benchmarking list designed to ensure a simple, fair and cost-efficient implementation of the EUDR. This list classifies countries according to their ‘low', ‘standard', or ‘high' risk of deforestation. The country classification takes into account the production of the seven commodities covered by the EUDR, namely cattle, cocoa, coffee, oil palm, rubber, soya and wood. These commodities have been chosen on the basis of a thorough impact assessment identifying them as the main driver of deforestation due to agricultural expansion. The publication of the benchmarking list follows a positive opinion by consensus of all EU member states.
The countries which are identified in the high-risk category in this first country benchmarking list are subject to sanctions from the UN Security Council or the Council of the EU on imports or exports of the relevant commodities and relevant products.
The publication of this country benchmarking is an important milestone ahead of the entry into application of the EUDR on 30 December 2025 for large companies and 30 June 2026 for micro and small companies.
The publication of the benchmarking list was accompanied by a Staff Working Document outlining the methodology on which the benchmarking is based.
For further information on any of these updates, please contact Jill Shaw, ESG & Sustainability Lead or any other member of the ALG ESG & Sustainability team.
Date published: 9 June 2025
