If you sit on a board or work in governance in Ireland, ESG reporting has probably been on your radar for a while now. With new rules, shifting deadlines, changing obligations, it can feel like the goalposts keep moving, so here is a guide to what has changed, and what Irish boards should be focused on right now.
What Is ESG Reporting and Why Does It Matter for Irish Companies?
ESG stands for Environmental, Social and Governance, and ESG reporting is about how organisations disclose their impact on the world, how they are governed, and the risks and responsibilities that come with running a business. For a long time, this kind of reporting was voluntary for most companies. That’s been changing rapidly across the EU.
The main piece of legislation is the Corporate Sustainability Reporting Directive, or CSRD. It came into Irish law through the European Union (Corporate Sustainability Reporting) Regulations 2024, which amended the Companies Act 2014 and came into effect on 6 July 2024. The aim was to bring more companies into a structured framework for sustainability disclosure, making those reports consistent, comparable, and independently assured.
For Irish companies within scope, sustainability reporting must sit within a dedicated section of the directors’ report. A separate standalone sustainability document is not permitted. Reports must also meet specific digital formatting requirements under the European Sustainability Reporting Standards (ESRS).
How Have the Rules Changed?
The original CSRD was designed to capture a wide range of companies. But in early 2025, the European Commission proposed major changes through what became known as the Omnibus package. After months of negotiation, the final Omnibus Directive was formally adopted and published in February 2026, coming into force on 18 March 2026.
Under the revised rules, mandatory CSRD reporting now applies only to the largest organisations, broadly those with more than 1,000 employees and more than €450 million in annual net turnover. That’s a significant narrowing from the original thresholds, which would have captured companies with 250 or more employees and €50 million in turnover. Around 80% of companies originally in scope have now been removed.
Listed SMEs are fully exempt under the revised framework. Financial holding companies also benefit from a new exemption.
If your Irish company was preparing for CSRD obligations and you have not recently reassessed your position against these updated thresholds, now is the time to do that.
Who Is Currently Reporting and Who Is Not?
There are three groups. The first group, made up of large public interest entities such as listed companies, banks and insurers with more than 500 employees, were already required to report under the predecessor Non-Financial Reporting Directive. These companies published their first CSRD-compliant reports in 2025, covering financial year 2024 and are still required to report.
The second group covers larger companies that were due to start reporting in 2026 for financial year 2025. Their start date has been pushed back by two years under the stop-the-clock mechanism. These companies now face mandatory reporting from 2028, covering financial year 2027. 2026 and 2027 should be used as preparation years, not quiet years.
The third group, listed SMEs, has been removed from scope entirely under the Omnibus.
For non-EU parent companies with subsidiaries or branches in Ireland, the revised threshold applies to groups generating more than €450 million in net annual turnover within the EU at group level, with the relevant EU entity generating more than €200 million in net turnover.
Is ESG Reporting About More Than Filing a Report?
Under the Companies Act 2014, directors have a legal duty to act with reasonable care and skill. That duty extends to considering the environmental and human rights consequences of board decisions.
If a board makes public statements about its sustainability commitments and fails to follow through, or if disclosures prove inaccurate, directors can face real scrutiny and potential personal liability. Irish governance professionals should factor this into how they approach ESG oversight at board level, not just at management level.
Does Your Company Need to Act Even If It’s Not in Scope?
This is a point that often gets missed in conversations about CSRD compliance in Ireland. Even if your organisation falls below the revised thresholds for mandatory reporting, ESG isn’t irrelevant to you.
Larger companies that are required to report must account for their value chains. That means your sustainability practices can become part of a larger company’s disclosure story whether you report independently or not. Customers, banks and investors are increasingly asking ESG-related questions of companies at every level, not just those caught by mandatory regulation. The commercial case for voluntary alignment is real and growing.
What Does the Research Say About Board Readiness?
Research published earlier this year by the Corporate Governance Institute, drawing on responses from 500 board directors and C-suite executives across the UK and Ireland, found a striking disconnect. While 85% of directors felt broadly confident in their board’s overall effectiveness, that figure dropped to just 35% when directors were asked specifically about their board’s readiness to handle governance and compliance challenges including ESG.
That gap between general confidence and specific capability is a risk in itself. Irish boards that want to lead on ESG governance rather than simply react to it need to be honest about where that gap exists within their own membership.
What Should Irish Boards Be Doing Right Now?
Check your headcount and turnover against the revised CSRD thresholds and establish clearly whether you have a mandatory reporting obligation, a supply chain obligation, or neither. The answer determines everything else.
Even boards not yet required to report formally will benefit from understanding their own sustainability data better. When the questions come, from regulators, investors, customers or value chain partners, you want to be able to answer them with confidence.
Monitor Irish domestic legislation. Ireland’s Department of Enterprise, Trade and Employment has confirmed it will update Irish law to reflect the Omnibus changes. The precise shape of your obligations as an Irish company will depend on those implementing regulations, so staying close to developments is important.
ESG literacy at board level is a baseline expectation. Directors need to be able to engage substantively with sustainability questions. Given what the research tells us about the current confidence gap, this is an area most Irish boards still have room to improve.
Why Does Governance Infrastructure Matter for ESG?
Managing the volume and complexity of information that modern boards need to engage with is a governance challenge in itself. Boards navigating ESG reporting obligations, gender diversity requirements, and pay transparency changes all at once need reliable processes for preparing, distributing, and tracking board materials.
Convene’s board portal helps governance teams do exactly that, keeping everything organised, secure, and accessible so that directors can focus on the decisions that matter.
Convene Board Portal allows decision makers to:
- Vote and Approve: Cast votes in and out of meetings and oversee all decisions in a dashboard. Review and sign off documents for approval.
- Sign with an eSignature: Add your signature and initials to documents instantly or sign via your preferred local e-signature provider to meet compliance needs.
- Take minutes: Create minutes before, during, or after meetings, with action items, votes and notes synced in real time with the option for AI minutes.
- Manage tasks: Assign tasks and track action item progress throughout the meeting cycle.
- Create an audit trail: Strengthen transparency and accountability with comprehensive audit reports covering meeting activity and information access.
- View a Dashboard: Get a view of your responsibilities so you don’t miss key deadlines or meetings.
- Browse the Document Library: Store and manage confidential documents in a central library with permissions set by file and folder.
These features can transform your board’s governance practices. Book a demo and maximise your board’s effectiveness today.
FAQs
What is the CSRD?
The Corporate Sustainability Reporting Directive (CSRD) is the main EU law governing sustainability reporting for companies. It came into Irish law in July 2024 through the European Union (Corporate Sustainability Reporting) Regulations 2024, amending the Companies Act 2014. In-scope companies must include a dedicated sustainability section within their directors’ report each year. A separate standalone sustainability document is not permitted.
Does ESG reporting apply to my Irish company?
It depends on your size. Under the revised rules introduced by the Omnibus Directive in 2026, mandatory ESG reporting now applies to companies with more than 1,000 employees and more than €450 million in annual net turnover. PwC Ireland estimates that only around 250 entities in Ireland remain in scope under these revised thresholds. If you fall below those figures, you’re not currently required to report, though you may still face ESG-related questions from customers, investors or larger companies in your supply chain.
What did the Omnibus Directive change?
The Omnibus Directive, which came into force on 18 March 2026, narrowed the scope of the CSRD significantly, raised the thresholds for mandatory reporting, removed listed SMEs from scope entirely, and pushed back reporting deadlines for companies not yet reporting. Ireland’s Department of Enterprise, Trade and Employment has confirmed it will update Irish domestic legislation to reflect these changes.
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