Corporate Sustainability Reporting Directive (CSRD)

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Understanding CSRD: navigating new sustainability reporting standards

The Corporate Sustainability Reporting Directive (CSRD) isn’t just about compliance — it’s your opportunity to embed sustainability into your core business strategy and build trust with stakeholders through transparent environmental, social and governance (ESG) reporting. This EU regulation expands sustainability disclosure requirements beyond the previous Non-Financial Reporting Directive (NFRD), covering more companies and demanding deeper insights into ESG impacts. We’re here to help you navigate CSRD requirements, so you can turn regulatory obligation into strategic advantage.

Current CSRD applicability in Ireland

CSRD entered into force in January 2023 and was transposed into national law in Ireland in July 2024 

In July 2025, Ireland gave legal effect to the EU’s “Stop the Clock” Directive which ensured that the original CSRD will not apply to so-called Wave 2 (large EU companies) and Wave 3 (SMEs) companies for a further two years respectively, while the European Commission’s Omnibus proposal is being negotiated and agreed. 

The link between CSRD and the ESRS

The CSRD requires companies to report reliable information on material sustainability-related impacts, risks and opportunities (IROs) across their value chains. 

This starts with a double materiality assessment (DMA), for which companies consider: 

financial materiality: effects on the business, expressed as risks and opportunities

impact materiality: effects on people and the environment.

The 12 European Sustainability Reporting Standards (ESRS) underpin the directive. These comprise two cross-cutting standards (which define general principles, concepts and disclosures) and ten topical standards that cover detailed reporting requirements for various environmental (climate change, pollution, water, biodiversity & ecosystems, resource use & circular economy), social (own workforce, workers in the value chain, affected communities, consumers and end users) and governance matters. They require companies to report material IROs they identify, including plans for addressing them. This includes:

  • disclosures on relevant policies
  • actions to manage risks and impacts
  • metrics to track progress. 

What are the changes in relation to the Corporate Sustainability Reporting Directive (‘CSRD’)?

In December 2025, the European Parliament and Council of the European Union reached a provisional agreement on certain aspects of the European Commission’s ‘Omnibus’ proposal, with the European Council indicating that it will officially approve the agreement also. The European Commission estimated the increased scoping thresholds for CSRD would reduce the number of in-scope companies by about 80%.  However, based on the latest proposed thresholds which are higher than those first envisaged by the European Commission,  (the final number of entities removed from the original scope will be even higher).

The ‘Omnibus’ agreement will be subject to a final vote after a legal and linguistic review of the text, and will come into force 20 days after publication in the Official Journal of the European Union expected around March 2026. EU Member States will have 12 months from publication in the Official Journal to transpose the text into national legislation.

The following table provides a comparison of the current requirements of CSRD, and the provisional agreement reached in December: 

The change to scope of entities that are required to report under the CSRD is applicable for financial years beginning on or after 1 January 2027.  

 

Current requirements (pre-Omnibus)

 

Provisional agreement4

 

Reporting for EU entities EU entities or groups that exceed at least two of the following size criteria:
  • 250 employees
  • €50 million net turnover
  • €25 million total balance sheet

EU entities or groups with: 

more than 1,000 employees on average during the financial year and 

more than €450 million net turnover

Reporting for non-EU entities with debt/equity listed on EU-regulated markets 

Non-EU entities with securities (equity or debt) admitted to trading (that is, ‘listed’) on an EU-regulated market

 

 

Non-EU entities with securities (equity or debt) admitted to trading (that is, ‘listed’) on an EU-regulated market with:

more than 1,000 employees on average during the financial year and 

more than €450 million net turnover 

Reporting for listed SMEs Small and medium sized enterprises (SMEs) listed on a regulated market Exclusion of listed SMEs

Additional global consolidated reporting for non-EU parent entities

 

Non-EU entities with a consolidated turnover exceeding €150 million in the EU; and either: 

a ‘large’ EU subsidiary (as defined) or listed SME subsidiary or 

an EU branch with turnover exceeding €40 million

Non-EU entities with consolidated turnover exceeding €450 million in the EU for each of the last two consecutive financial years; and either: 

an EU subsidiary with net turnover exceeding €200 million in the preceding financial year, or

an EU branch with net turnover exceeding €200 million in the preceding financial year 

Client priorities

Check if you are in scope of the revised CSRD 

  • Review the draft amendments to the ESRS on the EFRAG ESRS knowledge hub and continue to monitor updates as they progress through the finalisation stages.

  • Complete/update your double materiality assessment  so that 2026 can be used as a dry run period.

 

Understand the draft simplified ESRS and assess implications

  • Review the draft amendments to the ESRS on the EFRAG ESRS knowledge hub and continue to monitor updates as they progress through the finalisation stages.

 

  • Complete/update your double materiality assessment  so that 2026 can be used as a dry run period.

Consider reporting approach 

If not within the scope of CSRD, or your entities in scope period begins 1 January 2027 but there is some incentive to formalise reporting earlier, consider whether reporting under the VSME standards or some other voluntary standards (e.g. GRI) would align with your strategic objectives and communication strategy.

Helping you prepare for CSRD

With a skilled core team focused on Sustainability reporting and assurance, PwC can bring a wealth of experience and practical know-how to help your organisation achieve value as well as regulatory compliance.

CSRD scoping

Companies must determine if they fall within the scope of CSRD, and if so, if there are reporting options they can avail of. These are strategic decisions in terms of how your organisation is portrayed to key stakeholders. It is also important to consider alignment with your broader sustainability strategy and existing disclosed ambitions (e.g. net zero target date).

Strategy alignment

Navigating regulatory and data complexity is more challenging than ever. Shifting sustainability disclosure regulations and rising expectations around sustainability data are adding new layers of complexity. To make holistic and strategic business decisions, there is a need to seamlessly integrate diverse data sources and stay ahead of constant changes in regulation. 

The power of AI and technology can help you unlock insights and harness potential from your data to create more value in your business and keep you ahead in a fast-changing world. Leveraging your data can help design sustainable supply chains, rethink resource use, reduce carbon and navigate regulatory compliance.

Understanding the current landscape while keeping a keen eye on the future can help your business stay ahead of regulations, avoid potential disruption and penalties, and prepare for what’s next.

 

Double materiality assessment

The double materiality assessment is a core element of CSRD — acting as the bridge between a company’s core strategy and its ESG reporting. The concept requires the assessment of the two dimensions to double materiality: impact materiality and financial materiality, when identifying the information to be disclosed. This approach demands that companies evaluate their impact on environmental and social factors (the inside-out view) and assess how sustainability issues impact their risk profile and financial performance (the outside-in view). Our experience supporting those who have already reported under CSRD has given us great insight into topics relevant at each industry level as well as practical experience of how best to complete these assessments

CSRD roadmap and implementation support for reporting

Regardless of the maturity of existing non-financial reporting, this is a significant project for any organisation and identifying a roadmap and implementation plan at the outset is key. Businesses must identify stakeholders and obtain their buy-in, analyse existing sustainability reporting processes, and engage with key internal stakeholders to understand existing data management processes. This is particularly important given the scale of the ESRS, which, despite reductions in the recent amended ESRS, includes 314 separate data points for organisations to collect and report on.

Sustainability assurance

Mandatory limited assurance is required on CSRD reporting, which will increase the requirements for controls over the process and the data used for the increased disclosures. 

In-scope companies will need a robust internal framework for sustainability reporting, capable of adapting to changing requirements and withstanding rigorous external scrutiny. 

Many organisations benefit from completing pre-assurance readiness assessments prior to the live period of reporting. 

Time is limited when it comes to reporting. Therefore, involving your assurance practitioner early on in the development of your materiality assessment and documentation approach can be quite helpful. This will allow you to address any potential concerns about the process and available documentation upfront and ensure that there is enough time to align expectations before the start of the assurance engagement. 

CSRD and tax reporting

Incorporating tax reporting in the CSRD framework is a crucial factor for businesses striving for comprehensive sustainability compliance. It guarantees that tax strategies not only comply with regulations, but also reflect a commitment to societal and environmental responsibility. Transparent tax practices are essential, showcasing how tax contributions support broader sustainability objectives. To navigate this aspect of CSRD, a comprehensive understanding of both tax and sustainability reporting is necessary, ensuring that financial practices contribute positively to the company’s reputation and stakeholder relations.

Technical support through specific topics

The scope of the ESRS is wide, which inevitably means that organisations will need to report on areas that are new to them. In many instances the first step is understanding the technical requirements in detail and what the next steps are. We can help you break this down into actionable, practical steps including support on the documentation that your auditors will require to assure the data / statement.

Drafting your sustainability statement

Drafting your first sustainability statement can be a daunting prospect when faced with the list of datapoints within the ESRS. We help businesses draft and review CSRD disclosures, ensuring alignment with regulatory standards and consistency with your other reporting.

Why partner with PwC?

We can assist you on your Sustainability Reporting journey . Our team of experts has a wealth of cross-industry experience to create effective and client-centric solutions. Our collaborative approach helps us understand your business and its CSRD needs. And with PwC’s global network, we can leverage niche expertise and best practices from other regions to guide your company through the evolving corporate sustainability reporting landscape. If you are facing Sustainability reporting challenges and want to discuss them with us, contact us today.

Meet the CSRD team

Sustainability reporting stakeholders can trust.

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Contact us

Fiona Gaskin

Fiona Gaskin

Partner, PwC Ireland (Republic of)

Tel: +353 86 771 3665

Fidelma Boyce

Fidelma Boyce

Assurance Partner, PwC Ireland (Republic of)

Tel: +353 86 8128831

David McGee

David McGee

ESG Leader, PwC Ireland (Republic of)

Tel: +353 86 268 1522

Aidan Lucey

Aidan Lucey

Partner, PwC Ireland (Republic of)

Tel: +353 86 310 3568

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