Sustainability Reporting
SUSTAINABILITY REPORTING HUB
Our Sustainability Reporting Hub is a resource setting out legislation and guidance in relation to the CSRD, EU Taxonomy Regulation and CSDDD.
IRISH TRANSPOSITION OF “STOP-THE-CLOCK”
The European Union (Corporate Sustainability Reporting) Regulations 2025 implemented the two-year deferral of CSRD reporting obligations for “wave 2” and “wave 3” companies, in accordance with the “stop-the-clock” directive. The regulations also address anomalies in the original Irish transposing legislation, including the definition of “turnover”. For further details, please see our update: Ireland Transposes ‘Stop-the-Clock’ Directive and Clarifies CSRD Scope .
OMNIBUS AMENDMENTS TO CSRD AND CSDDD
The European Parliament is expected to adopt its negotiating position on the Commission’s Omnibus proposals to amend the CSRD and CSDDD later this month, with indications that it will favour raising the employee threshold for CSRD scope alongside a turnover threshold of EUR 450 million. Trilogue negotiations with the Council are anticipated to begin in November, and there is political momentum to reach agreement on the final text by year‑end.
HORIZON SCANNING
30 November 2025
EFRAG to deliver technical advice on revised ESRS
1 January 2026
Amendments to Taxonomy reporting framework due to apply
1 January 2026
CBAM applies in full
ESRS
ESRS Revision
EFRAG’s public consultation on exposure drafts of the revised ESRS closed on 29 September. Feedback on the exposure drafts will form part of EFRAG’s technical advice to the European Commission on revision of the ESRS, which is due to be delivered by 30 November 2025.
“Quick Fix” for “Wave One” Companies
The European Commission adopted the ESRS “Quick Fix” Delegated Act, removing the obligation for “wave 1” companies to report additional information for financial years 2025 and 2026 and extending certain phase-in reliefs, previously only available to companies with less than 750 employees, to all “wave 1” reporting companies. The delegated act will apply for financial years beginning on or after 1 January 2025. More information is set out in the summary of the ESRS modifications.
ESRS “2025 State of Play” Portal
EFRAG launched an ESRS Statistics and Report portal, presenting insights from early implementation of the ESRS.
EU TAXONOMY SIMPLIFICATION
On 4 July 2025, the European Commission adopted a delegated act to simplify Article 8 Taxonomy disclosure requirements, including the introduction of a materiality threshold, as outlined in our update: EU Taxonomy: Simplification Measures Adopted.
The delegated act is currently under scrutiny by the European Parliament and the Council. Following a two-month extension agreed on 6 October 2025, the institutions now have until 5 January 2026 to object. If no objection is raised within that period, the delegated act will enter into force in the usual way.
If approved, the amendments to the Taxonomy reporting framework would apply to reports published from 1 January 2026 (covering the 2025 financial year) for companies currently within scope of the EU Taxonomy regime. For that reporting period, in-scope companies may opt to continue reporting under the current framework rather than applying the amended requirements.
The Commission is also launching a comprehensive review of Taxonomy reporting requirements and the technical screening criteria, including the "do no significant harm" criteria.
EUDR: POTENTIAL POSTPONEMENT
The European Commission has suggested a postponement of the entry into application of the EU Deforestation Regulation (EUDR) by one year, citing capacity issues with the IT systems used to process due diligence statements. If approved, this delay would push the implementation date from 30 December 2025 to 30 December 2026. This would be the second postponement of the EUDR, which was originally due to take effect from 30 December 2024 but was delayed by 12 months last year.
CBAM: SIMPLIFICATION AND IMPLEMENTATION
The Council has formally adopted amendments to the Carbon Border Adjustment Mechanism (CBAM) the as part of the Sustainability Omnibus package. A key change is the introduction of a de minimis exemption for importers of less than 50 tonnes of CBAM goods per year, alongside streamlined compliance obligations, as outlined in our update: Carbon Border Adjustment Mechanism.
CBAM will take full effect from 1 January 2026, and the European Commission is currently finalising Implementing Regulations to support effective operation of the regime, including authorisation and reporting mechanics for authorised CBAM declarants. For more see our recent update: CBAM: Consultation on Implementing Regulations.