Corporate Reporting

CBAM: CERTAIN PROVISIONS APPLY AHEAD OF FULL REGIME

The Carbon Border Adjustment Mechanism (CBAM) currently applies to importers of cement, iron and steel, aluminium, fertiliser, electricity and hydrogen from outside of the EU. It is designed to apply the same carbon costs to those goods as would have been incurred had they been produced in the EU.

Transitional reporting obligations under CBAM have applied since 1 October 2023 and run until 31 December 2025.

While the bulk of provisions implementing the full CBAM begin to apply from 1 January 2026, some provisions apply from 31 December 2024, including a requirement for importers (or their indirect customs representative) to apply for the status of authorised CBAM declarant prior to importing in-scope goods into the EU.

For more on CBAM, see our Insights: Carbon Border Adjustment Mechanism: Provisions applying from Q4 of 2024.

GENDER PAY GAP REPORTING: LOWER THRESHOLD APPLIES

In 2025, employers who employ 50 employees or more will come into scope for gender pay gap reporting in Ireland for the first time. To date, only employers with 150 employees or more are required to report. The Government has indicated that other changes to the gender pay gap reporting regime may be introduced this year, including that the reporting deadline may be brought forward from December to November of each year and that a central online reporting system operated by the Department of Children, Equality, Disability, Integration and Youth may become operational.

For more, see the Insights from our Employment Group: Changes to gender pay gap reporting for 2024.

FRC REVIEW OF CORPORATE GOVERNANCE REPORTING 2024

The FRC published its annual Review of Corporate Governance Reporting, reviewing reporting during 2024 against the UK Corporate Governance Code. The review emphasises the continued importance of the UK Code’s “comply or explain” approach - while companies are making good use of this flexibility, the review identifies areas for improvement, particularly in internal controls reporting, the quality of explanations when companies depart from the UK Code and the need for more concise, outcomes-focused disclosure (a key area of focus in the 2024 UK Code).

For more, see our Insights: FRC Annual Review of Corporate Governance Reporting.

ESEF: 2024 UPDATE

ESMA published the 2024 ESEF XBRL taxonomy files and an update to the ESEF Conformance Suite to facilitate implementation of the ESEF Regulation, an update to which was published on 15 January 2025, and to reflect the 2024 update to the ESEF Reporting Manual. Under the ESEF Regulation, all issuers with securities listed on an EU regulated market must prepare their annual financial reports in XHTML and mark-up the IFRS consolidated financial statements using XBRL tags and iXBRL technology.

These documents are designed to assist issuers in preparing 2024 IFRS consolidated financial statements using the most updated version of the ESEF format. Issuers may alternatively use the 2022 ESEF taxonomy files and conformance suite published by ESMA in December 2022, for annual financial reports concerning financial years beginning on or after 1 January 2024.

FRC: DISCUSSION PAPER ON DIGITAL REPORTING

The FRC recently consulted on potential alternatives to the ESEF taxonomy for UK listed companies. The FCA is keen to explore whether the FRC should offer an alternative taxonomy to support digital reporting under the Disclosure Guidance and Transparency Rules or whether issuers would prefer to use the FRC’s existing UKSEF approach.