Sustainability reporting update – Irish legislation amended and “quick fix” delegated act adopted

On 11 July 2025, amendments to corporate sustainability reporting obligations were announced at both national and European levels. In Ireland, the European Union (Corporate Reporting) Regulations 2025 (the Regulations) were published. At an European level, the European Commission announced the adoption of a delegated act which introduces “quick fix” amendments to the European Sustainability Reporting Standards (ESRS). These amendments will apply to those companies that had to start reporting sustainability information under the Corporate Sustainability Reporting Directive for the 2024 financial year (“wave one” companies).   

Irish update

The Regulations implement the provisions of the Stop the Clock Directive ensuring that those Irish companies required to report for the first time in respect of their 2025 or 2026 financial years have their sustainability reporting obligations pushed out by two years, to 2027 and 2028 respectively. Amendments have been introduced to the Companies Act 2014, as amended (the Companies Act) and the Transparency Regulations 2007, as amended.

The Regulations also introduce amendments to the Companies Act to clarify certain of the provisions introduced by the European Union (Corporate Sustainability Reporting) Regulations 2024 (2024 Regulations) including:

• clarifying the use of company size criteria and rectifying an anomaly in the 2024 Regulations which had brought certain entities (such as small, unlisted PLCs and those authorised by the Central Bank of Ireland) within scope simply because they are “ineligible entities” under the Companies Act
• amending the “net turnover” definition to remove reference to companies “whose ordinary activities include the making or holding of investments”, aligning the definition more closely with that in the Accounting Directive
• introducing language that permits Irish subsidiaries with EU parents to avail of the subsidiary exemption and
• that the provisions on sustainability reporting concerning third country undertakings are relevant in the context of ultimate parent undertakings

EU update

The adoption of the “quick fix” delegated act has been eagerly awaited by wave one companies as it provides certainty on the types of information that will need to be included in the sustainability statement for the 2025 and 2026 financial years.

Wave one companies were permitted to omit certain information for their first year of reporting. Once this delegated act is finalised, these companies will be able to continue omitting such information for their 2025 and 2026 financial years. Furthermore, wave one companies with more than 750 employees will benefit from most of the phase-in provisions that currently apply to companies with up to 750 employees. Areas where reporting obligations would have expanded if these quick fix amendments were not introduced include anticipated financial effects; a company’s own workforce; biodiversity and ecosystems; workers in the value chain; affected communities; and consumers and end users. The European Commission also published a summary of the modifications being introduced.

The act is subject to a two-month scrutiny period by the European Parliament and Council before it can be finalised and published in the Official Journal of the EU. Unless an extension of this scrutiny period is requested, the act should be published in the early autumn.    

For further information on these updates, please contact Jill Shaw, Anne O’Neill or any other member of the ALG ESG & Sustainability team.

Date published: 16 July 2025