Wave One, Year Two: What Ireland’s second year of CSRD reports are telling us

PwC Ireland has reviewed the first 13 Irish “Wave One, Year Two” sustainability statements (covering financial years beginning on or after 1 January 2025) to understand what is changing in practice, where common challenges remain, and what preparers should prioritise as we move towards the next reporting cycle.

The context: CSRD year two amid a year of disruption and moving goalposts

For those working within sustainability, 2025 was a rollercoaster — shaped by regulatory uncertainty, geopolitical volatility, extreme weather and fractured supply chains. Against that backdrop, many organisations were trying to do two things at once: meet fast-evolving regulatory expectations and continue to deliver on their sustainability strategy in a world where operational resilience was being tested in real time.

In February 2025, the European Commission (EC) published its first Omnibus Simplification Package in response to growing concerns about the complexity, burden and cost of sustainability regulation, particularly for smaller companies. The intent was clear: simplify reporting requirements, ease administrative load and still protect the integrity of sustainability standards. In practice, however, it also introduced a new question for many organisations: who, exactly, needs to report what — and when — for financial year 2025 and beyond?

That uncertainty eased somewhat in April, when the Stop-The-Clock Directive was approved. This moved out the reporting requirements under CSRD by two years for companies who had been due to start reporting from financial years 2025 and 2026 (the so‑called “Wave Two” and “Wave Three” companies). Wave One companies were not captured by the Stop-The-Clock Directive. So, while the timetable shifted for many, the first movers still had to deliver.

In July 2025, the EC adopted targeted quick fix amendments to the first set of European Sustainability Reporting Standards (ESRS) to reduce the burden and increase certainty for Wave One companies. The delegated act removed the requirement for Wave One companies to provide additional information for FY25 and FY26, and it extended certain phase‑in reliefs that had previously been limited to companies with fewer than 750 employees. Put simply: the quick fix was necessary because Wave One companies — already reporting — were not the beneficiaries of “stop‑the‑clock”.

Alongside these immediate measures, the first Omnibus package also set a longer-term direction of travel: revisions to the ESRS. The proposed approach points to fewer data points overall, a greater emphasis on quantitative disclosures (rather than qualitative narrative), and stronger consistency with other EU legislation. Although various drafts were published throughout the year, these revisions are still in progress — meaning Wave One companies had to report against the original ESRS issued in 2023.

And while the agreement reached in December 2025 (and the subsequent Directive adopted in February 2026) may mean that some companies ultimately fall out of scope of CSRD, the current legislation still prevails until Ireland transposes the Omnibus Directive into national law (no later than 19 March 2027).

The Irish Wave One picture: a small cohort, big learning curve

In Ireland, the Irish Auditing & Accounting Supervisory Authority (IAASA) noted that 20 entities were in scope to publish sustainability statements for financial years beginning on or after 1 January 2024 (Wave One). Last year, three availed of an exemption from preparing an individual sustainability statement because they were included in a group or intermediate parent sustainability statement.

For year two, our analysis covered 13 sustainability statements published by Wave One companies in Ireland (76% of standalone reports expected from Irish companies in scope of CSRD for FY25).

The majority are in the financial services sector and 92% had a 31 December year-end.

Report length ranged from 40 to 175 pages (63 to 181 in FY24), with the average length decreasing by 11%.¹

Only one published an additional separate sustainability report and most did not disclose a GRI index or a SASB index. None reported under TNFD while 62% reported under, or mapped their disclosures to, TCFD.

The message is clear: organisations are beginning to refine their approach — tightening length, improving structure — while still grappling with what “good” looks like under ESRS in practice.

Assurance opinions issued

Limited assurance is no longer something to “add on” at the end of the process; it is shaping how organisations think about data, controls, documentation and governance.

Among the 13 sustainability statements reviewed:

• Four audit firms provided limited assurance over sustainability statements.

• All but one appointed their local statutory auditor to perform the required limited assurance engagement. In the case of the one organisation who did not appoint their local statutory auditor, the group auditor was appointed.

• 38% had the same individual sign both the limited assurance report and the financial statement audit report.

In our sample, there was one qualified opinion linked to water-related metrics and an inability to “obtain sufficient appropriate evidence to verify the accuracy and completeness of the metered data”.

All the reports included inherent limitations with the most common ones identified in the assurance report relating to:

• forward-looking information

• estimates, approximations and third-party data

• greenhouse gas emissions and their quantifications

• new and evolving standards

• key estimates and judgements

• interpretation of undefined legal and other items

• value chain information

• adopted measurement methodologies

• may not include every IRO/entity topic that each stakeholder considers important.

For preparers, this reinforces a practical point: the assurance lens is increasingly influencing how disclosures are evidenced, and where organisations need to invest in data foundations.

EU Taxonomy: simplified rules, mixed approaches

The Commission Delegated Act simplifying the application of the EU Taxonomy Regulation was published on 8 January 2026 during annual report finalisation.

Among the 13 sustainability statements reviewed:

• 54% elected to avail of the transitional option permitted and applied the previous regime for their FY25 reporting.

• 38% elected to report under the simplified EU Taxonomy reporting requirements.

• one entity deferred EU Taxonomy reporting until 2027 under the Simplification Delegated Act (and stated that no activities were claimed as taxonomy-aligned).

The location of the taxonomy disclosures within the sustainability statements differed with many opting to cross-reference within the environmental section and then include at the end of the sustainability statement. In some instances, the EU taxonomy tables were included outside the sustainability statement in an appendix at the end of the annual report.

The broader takeaway: simplification does not automatically mean consistency with the possibility of a similar challenge in next year’s reporting based on the amended ESRS requirements and potential options included therein.

Quick-fix relief used selectively

The “quick fix” amendment allowed Wave One entities to omit all information under E4 — Biodiversity, S2 — Workers in the value chain, S3 — Affected communities and S4 — Consumers and end-users for FY25 and FY26. Wave one companies that used this temporary exemption for a complete topical standard must nevertheless report certain summarised information on the topic concerned if they conclude that the topic in question is material (see ESRS 2, General Disclosures, paragraph 17).

Among the 13 sustainability statements reviewed:

• 38% availed of the relief, in some instances reporting shorter sections than the prior year.
• not applicable for 15% as these companies did not report on any of the topics within scope of the amendment (for example only had ESRS E1, S1, G1 as material).

This points to a pragmatic response: organisations are using available reliefs, but often in a targeted way — balancing workload reduction against stakeholder expectations and the desire to demonstrate progress and consistent messaging.

What’s material in practice: climate and workforce dominate (again)

Material topic reporting continues to show a clear pattern.

Among the 13 sustainability statements reviewed:

• E1 — Climate change and S1 — Own workforce were material for all.
• G1 — Business conduct and S4 — Consumers and end-users were also among the most common.
• least reported topic was E2 — Pollution.
• two noted only three topics as material and two others noted all ten. topical standards as material — illustrating the breadth that is possible, but also the variability in scope across the Irish market.
• there was also integration of previously standalone, entity-specific topics into sub-topics within an ESRS (for example, cybersecurity as a sub-topic within ESRS S4/G1).
• double materiality refreshes focused on building on prior year.

CSRD sustainability reporting under ESRS is annual, which means that companies must consider, at each reporting date, their material impacts, risks and opportunities (IROs) and the information required for disclosure.

However, where a company can evidence that the prior year materiality assessment remains valid, it may reuse previous conclusions — for example, where there have been no material changes in the organisation’s structure or operations, and no material shifts in external factors that would create new IROs or change existing ones.

Typical trigger events that would require a refresh include major M&A, significant supplier or supply chain changes, relevant global events, entering or existing markets, or business lines, and shifts in social expectations, scientific evidence, or user needs.

Overall, the analysis performed for each reporting period should be sufficiently robust and proportionate to capture changes from the previous period(s), including in the value chain. While an annual update may focus on what has changed, the materiality assessment remains a dynamic process that should be kept under review on an ongoing basis.

All stated that they reviewed their double materiality assessment (DMA) during the period with most describing a refresh that built on the prior year in a mix of top-down and bottom-up approaches, with no material changes to methodologies. Considerations included changes in the sustainability reporting boundary compared to the prior year, market insights, regulatory change, peer reporting, emerging sustainability topics, principal risks and evolving or emerging risks. However, a recurring observation was that DMA refreshes generally did not include external stakeholder engagement, or that engagement was not clearly described.

The DMA refreshes led to changes in the number of underlying IROs year-on-year including:

• range of material IROs decreased from between seven and 56, to between six and 52.
• average number of positive impacts decreased from nine to eight.
• average number of negative impacts, risks and opportunities remained relatively stable.

Rationales for changes to IROs included:

• streamlining the language/revised wording for clarity.
• no longer meeting criteria for material disclosure.
• positive impacts already covered by local legislation.
• incorporation of emerging and evolving risks identified through the main risk management process.
• documenting impacts, risks and opportunities separately.
• more granular split between value chain activities to be able to assess at a more specific level.
• review of positive impacts in line with CSRD guidance published in the year.

There were also minimal changes in potential impacts to actual year-on-year.  

IRO benchmarking: where comparability still breaks down

While many reporters included summary tables of IROs or described them within the relevant sections, there could still be challenges in comparability when completing a benchmarking exercise. Challenges included differentiating between impacts, risks or opportunities, positive or negative impacts, actual or potential impacts and identifying which sub-topic an IRO referred to. There were also practical reasons to support why some IROs were linked to an ESRS topic even though a specific sub-topic did not exist. For these reasons, readers may need to exercise additional judgement when interpreting topics and comparing reports.

The year two challenge: doing better under moving rules

As identified by IAASA in 2025, Wave One entities had anticipated ongoing challenges in balancing readability, meaningfulness, comparability and completeness with questions persisting around the appropriate level of detail, what constitutes sufficient information and when reporting becomes excessive. 

Our discussions with a number of Wave One, Year Two reporters highlighted several key challenges including:

• practicalities of what constitutes a restatement and what needs to be disclosed.
• practicalities of assurance reviews in year two (sampling versus analytics).
• explaining year-on-year changes in material topics/IROs.
• managing version control and internal signoffs.
• presenting comparative information.
• changing auditors (or change of team members within existing audit team).
• data quality and practical considerations around time lags relating to source data.
• identifying the most appropriate emission factor to use.
• connectivity with financial statements, including with principal and emerging risks.
• differing interpretations of CSRD across Europe.
• uncertainty over when and how to apply amended ESRS and evolving requirements.

We’re here to help

PwC Ireland works with clients across the CSRD journey — from DMA refresh and ESRS gap assessments to data readiness, governance and assurance support — helping organisations move from compliance to mature, decision-useful sustainability reporting. If you’d like to discuss what these year two insights mean for your 2026 reporting plan, please get in touch.