Corporate Sustainability Reporting Directive (CSRD)

The Omnibus Simplification Package

On 26 February 2025, the European Commission (EC) published the first Omnibus Simplification Package. The Omnibus Simplification Package is the EC’s response to growing concerns about the complexity, burden and cost of sustainability regulations, particularly on smaller companies. Designed to simplify reporting requirements, it aims to reduce administrative burdens while maintaining sustainability standards. The package introduces key changes to major sustainability frameworks, which include the CSRD, the CSDDD, the EU Taxonomy for sustainable activities, and the Carbon Border Adjustment Mechanism (CBAM).

The ‘Omnibus’ package included a draft directive referred to as the ‘content’ proposal which would reduce the scope of entities subject to CSRD as well as the extent of reporting in accordance with the European Sustainability Reporting Standards (ESRS).  

To allow time for negotiation and adoption of this proposal, the European Parliament and Council of the European Union adopted a ‘stop the clock’ directive in April 2025, which delays first time application of CSRD for certain entities. In July 2025, the Minister for Enterprise, Tourism and Employment, Peter Burke, signed a Statutory Instrument to give legal effect in Ireland to the EU’s “Stop the Clock” Directive on Corporate Sustainability Reporting providing much-needed legal certainty to Irish business. This ensured that the original Corporate Sustainability Reporting Directive (CSRD) will not apply to so-called Wave 2 and Wave 3 companies for a further two years respectively, while the European Commission’s Omnibus proposal is being negotiated and agreed.

In addition, to provide relief to entities currently reporting under CSRD (‘wave 1’ reporters), on 11 July 2025, the European Commission adopted the ‘quick fix’ delegated act. This extended certain phase-in provisions that were previously only available to companies with less than 750 employees to all “wave 1” companies for FY2025 and FY2026. 

In November 2025, the European Parliament adopted a negotiating position regarding the first ‘Omnibus’ package, which included changes such as a reduction in reporting obligations and due diligence requirements for businesses.

The following table provides a comparison of the proposals – subject to trilogue negotiation – from the European Parliament, the Council, and the European Commission: 

Helping you prepare for CSRD

Reporting under CSRD is new for affected organisations, and guidance and standard practices are evolving. With a skilled core team focused on ESG 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

In today’s rapidly evolving business landscape, aligning core business strategies with ESG principles is a moral and strategic imperative. Consideration of the relevance of ESG  should be a lens that is applied to core strategy—not something that is managed separately. Often, ESG considerations have been informally considered as part of the existing strategy, but the linkage between the topics is not clear. In other cases, opportunities to pursue new areas of growth are identified through the longer term consideration of ESG topics. Where risks are identified, plans to minimise reputational damage and financial losses are key, as stakeholders and regulators demand accountability and transparency. As business leaders navigate these challenges, they must focus on creating a synergy between profit and purpose, ensuring that their companies survive and thrive in the new ESG-focused global business landscape.

Double materiality assessment

CSRD’s double materiality assessment is a complicated process for businesses, but 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). To fully understand their ESG impacts, companies need to carry out a comprehensive assessment of their operations and strategies. This involves collecting, analysing and reporting data—all of which requires significant resources and expertise as well as input from external stakeholders.

CSRD roadmap and implementation support for reporting

CSRD will apply to the first wave of in-scope companies for fiscal years starting on or after 1 January 2024 (filing reports in FY2025), so time is of the essence. 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. To ensure compliance, businesses must appoint a project owner, identify stakeholders and obtain their buy-in, analyse existing sustainability reporting processes, and engage with key internal stakeholders to understand existing data management processes.  

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

Given the requirement to report on a wide range of topics, and to then obtain limited assurance on that disclosure, many organisations have benefited by firstly focusing on a number of pilot projects whereby the data source and underlying processes and controls are established. This model can then be expanded to other areas of reporting.  

CSRD implementation can be a significant endeavour. The scale of the data collection challenge, spanning all aspects of an organisation, often requires complex delivery programmes covering changes to data models, systems and operating models. To ensure compliance, businesses must appoint a project owner, identify stakeholders and obtain their buy-in, analyse existing sustainability reporting processes, and engage with key internal stakeholders to understand existing data management processes.

Mandatory assurance

Mandatory assurance is required on CSRD reporting, which will increase the requirements for controls over the process and the data used for the increased disclosures. Initially requiring limited assurance, this mandate will evolve to reasonable assurance over time. The challenge is not only in achieving compliance, but also in maintaining it consistently as standards evolve. Many organisations benefit from completing pre-assurance readiness assessments prior to the live period of reporting. In-scope companies will need a robust internal framework for sustainability reporting, capable of adapting to changing requirements and withstanding rigorous external scrutiny. 

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.

CSRD training

A significant challenge posed by the CSRD is embedding sustainability knowledge within organisational structures. This reporting requirement will drive changes across all businesses, from compliance to procurement to HR. Companies must acquire technical reporting knowledge on sustainability and integrate it into their operations. This involves understanding various ESG metrics, which vary significantly across industries and company sizes. Companies must ensure compliance by integrating sustainability into decision-making processes. To achieve this, companies must invest in training and development for their people, management and board, and stay up-to-date on evolving sustainability practices and standards.

Why partner with PwC?

We can assist you on your journey towards CSRD compliance. 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 CSRD challenges and want to discuss them with us, contact us today.