SUSTAINABILITY REPORTING: OMNIBUS PACKAGE
A material update is expected from the European Commission on 26 February 2025 relating to a Simplification Omnibus package intended to cover a "far reaching simplification" for sustainability reporting, due diligence and taxonomy under the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CS3D) and EU Taxonomy Regulation.
The omnibus package is anticipated to take the form of a proposal for an EU regulation amending the texts of the current legislation. The European Commission confirmed in its recently published "Competitiveness Compass" that the omnibus will "ensure better alignment of the requirements with the needs of investors, proportionate timelines, financial metrics that do not discourage investments in smaller companies in transition, and obligations proportionate to the scale of activities of different companies." It is not yet clear whether the proposed "simplification" will include a broader revision of obligations under the CSRD, CS3D and EU Taxonomy Regulation.
The omnibus is a significant development which we are closely monitoring, and we will provide an update once further details are available.
For more information, read our Insights: Sustainability Developments: Possible Omnibus Simplification Package for Reporting.
CSRD: SECOND PHASE OF REPORTING COMMENCES
Sustainability reporting obligations under the CSRD as transposed into Irish law commence for entities within the second phase of reporting, for financial years commencing on or after 1 January 2025 (reporting year 2026), including large Irish-incorporated companies (which are not already in-scope under the first phase of reporting).
For more, read our Insights: Corporate Sustainability Reporting Directive.
SUSTAINABILITY REPORTING: LIST OF ASSURANCE PROVIDERS
The CRO is maintaining a list of firms and statutory auditors approved by Chartered Accountants Ireland under Part 28 of Companies Act 2014 to carry out the assurance of sustainability reporting.
CSRD: ESRS IMPLEMENTATION GUIDANCE
EFRAG continues to develop implementation support and guidance for companies reporting sustainability information in accordance with the ESRS. Recent updates include:
- ESRS Q&A: EFRAG published the latest batch of Explanations on its ESRS Q&A Platform, providing explanations for five new environmental questions related to climate change mitigation and adaptation targets, biodiversity and ecosystems.
- Transition Plans: EFRAG's draft transition plan implementation guidance is expected to be released for public consultation shortly.
- Voluntary Sustainability Reporting Standard: EFRAG has also published a voluntary sustainability reporting standard for non-listed SMEs, aimed at undertakings that are not within scope of the CSRD, to assist them in responding to requests for sustainability information.
For more, see our Insights: CSRD: Recent Developments for Sustainability Reporting.
SUPPLY CHAINS: EUDR OBLIGATIONS POSTPONED UNTIL DECEMBER 2025
The EU Deforestation Regulation (EUDR) prohibits operators and traders from trading on or exporting from the EU market certain commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and specified derived products, unless they are confirmed to be "deforestation-free" following due diligence on the supply chain.
Obligations under the EUDR had been due to come into effect from 30 December 2024, however the European Commission approved a 12-month delay in order to allow a phasing-in period to ensure effective implementation. EUDR obligations will now come into force from 30 December 2025 (and from 30 June 2026 for SMEs).
For more, see our Insights: EU Deforestation Regulation: Proposed Delay and EUDR: New Supply Chain Obligations for Relevant Commodities and Products.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.
