The Omnibus agreement sets a revised CSRD scope. EU entities with over 1,000 employees and net turnover above €450 million must apply the European Sustainability Reporting Standards (ESRS) and taxonomy rules for financial years starting on or after 1 January 2027. The threshold for non‑EU entities has also changed, with reporting required from financial years starting on or after 1 January 2028.
Applicability of CSRD in Ireland
CSRD came into force in January 2023 and was transposed into Irish law through the European Union (Corporate Sustainability Reporting) Regulations, which came into effect in July 2024.
In July 2025, Ireland gave legal effect to the EU’s “Stop the Clock” Directive. This move paused the original CSRD requirements for Wave 2 (large EU entities) and Wave 3 (small and medium-sized enterprises (SMEs)) for a further two years while negotiations on the European Commission’s Omnibus proposal continue.
Changes to the CSRD scope
Originally, the European Commission estimated that higher scoping thresholds would reduce the number of in‑scope entities by about 80%.ii However, the latest proposed thresholds go further, meaning even more entities will fall outside the scope of CSRD. Current estimates suggest that only around 250 entities in Ireland may remain in scope under the revised CSRD.iii
The table below compares the current CSRD requirements with the provisional agreement reached in December. The revised scope will apply to financial years starting on or after 1 January 2027.
| Current requirements (pre‑Omnibus) | Provisional agreement (Omnibus) | |
|---|---|---|
Reporting for EU entities
|
EU entities or groups that exceed at least two of the following size criteria:
|
EU entities or groups with:
|
Reporting for non‑EU entities with debt/equity listed on EU‑regulated markets
|
Non‑EU entities with securities (equity or debt) admitted to trading on an EU‑regulated market.
|
Non‑EU entities with securities (equity or debt) admitted to trading on an EU‑regulated market and:
|
| Reporting for listed SMEs | Small and medium‑sized enterprises listed on a regulated market.
|
Listed SMEs are excluded. |
Additional global consolidated reporting for non‑EU parent entities
|
Non‑EU entities with consolidated EU turnover above €150 million and either:
|
Non‑EU entities with consolidated EU turnover above €450 million for each of the last two consecutive financial years and either:
|
In the interim, the Omnibus agreement allows member states to exempt entities with less than €450 million in net turnover and fewer than 1,000 employees (on a consolidated basis, where relevant) from reporting obligations for financial years starting between 1 January 2025 and 31 December 2026. Each member state will determine how this exemption applies in practice.iv
The provisional agreement also introduces a new scope exclusion for parents of groups defined as ‘financial holding undertakings’. These undertakings may choose whether to include or omit consolidated sustainability information. The Omnibus agreement states that the exemption is only applicable where the undertaking has “diverse holdings, namely in undertakings whose business models and operations are independent of each other”.
Who reports, and when, under the provisional agreement
The following table outlines who will need to report when, based on the provisional agreement reached in December.
| Prior Application | Criteria |
FY2025 (Reporting 2026) |
FY2026 (Reporting 2027) |
FY2027 (Reporting 2028) |
FY2028 (Reporting 2029) |
|---|---|---|---|---|---|
Wave 2 (FY2025)
|
EU entities and groups and Non‑EU entities with debt/equity listed on EU‑regulated markets with: >1,000 employees and >€450m net turnover |
No * |
No * |
Yes — revised ESRS and revised EU Taxonomy |
Yes — revised ESRS and revised EU Taxonomy |
| EU entities and groups and Non‑EU entities with debt/equity listed on EU‑regulated markets with: <1,000 employees and/or <€450m net turnover | No * |
No * |
No |
No |
|
Wave 3 (FY2026) |
Listed SMEs, small credit institutions, captive (re)insurance undertakings |
No |
No * |
No |
No |
| Non‑EU headquartered entities with significant activities in the EU (FY2028) | Non-EU entities with consolidated EU turnover >€450m, plus either an EU subsidiary or branch with net turnover >€200m |
No |
No |
No |
Yes — using NESRS (European Sustainability Reporting Standards for non‑EU groups; to be developed) |
Non-EU entities with consolidated EU turnover <€450m and/or no EU subsidiary or branch with net turnover >€200m |
No |
No |
No |
No |
* Dependent on transposition of CSRD, in cases where the directive has previously been transposed into national law of the entity’s Member State, but “stop-the-clock” has not yet been transposed, then the reporting obligation may remain. Member States had until December 31 2025 to transpose the "stop the clock" directive into national law.
Other notable updates
- Value chain: The value chain cap would apply directly to reporting entities. Requests from entities with up to 1,000 employees would be limited to the requirements set out in the future Voluntary Sustainability Reporting Standard for Micro, Small and Medium‑Sized enterprises (VSME) Delegated Act.
- Assurance: The requirement for reasonable assurance is removed. The European Commission plans to adopt a limited assurance standard by July 2027.
- VSME: Entities now outside the mandatory scope of CSRD can choose to report voluntarily using the forthcoming VSME. The European Commission will issue a delegated act containing this standard.
- ESRS: The ESRS will be updated to reduce the reporting burden. Changes include a sharp reduction in mandatory datapoints, prioritisation of quantitative disclosures, and stronger consistency with other EU legislation.
- Sector standards: The obligation to issue sector‑specific standards is removed. The European Commission may develop sector guidance where demand arises from entities within a given sector.
What’s next?
The Omnibus agreement will go to a final vote once legal and linguistic reviews are complete. It will come into force 20 days after its publication in the Official Journal of the European Union which is expected around March 2026. From that point, EU member states will have 12 months to transpose the text into national legislation.
Practical steps to prepare for the revised CSRD scope
The provisional agreement reshapes who must report, when, and to what extent. While the detail varies by scope, every entity can take practical steps now to strengthen its readiness and adapt to the changes ahead.
The actions below group what matters most depending on whether you’re in scope or out of scope so you can plan with confidence.
We’re here to help you
Our specialists work at the heart of CSRD, ESRS and global sustainability reporting developments, bringing the technical insight and practical experience you need to navigate the changes with confidence. For more detail on the technical advice behind the simplified ESRS, you can explore our ‘In Depth’ on PwC Viewpoint.
If you want to understand what the Omnibus Simplification Package means for your entity, we can help you assess the implications, shape your reporting approach and fast‑track your readiness, so you can move forward with clarity. Get in touch today.
Omnibus Simplification Package
The Omnibus Simplification Package explained
Simplified European Sustainability Reporting Standards
Key takeaways from the changes.
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