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Corporate Sustainability Reporting Directive Update

Transposition of ‘Stop the Clock’ Directive and Resolution of Previous Statutory Instrument (S.I.) Anomalies in Ireland

On 7 July 2025, Ireland transposed the amending Statutory Instrument (S.I.) for corporate sustainability reporting, providing certainty to wave two reporters who were originally due to report from FY2025. This update provides a summary of the key matters addressed in the S.I.

Key Updates in the Statutory Instrument

  1. Transposition of the ‘Stop the Clock’ EU Directive into Irish Law: This directive provides legal certainty for wave two and wave three reporters, allowing a two-year deferral in reporting requirements for FY25 and FY26. Current wave one reporters must continue to comply with sustainability reporting obligations.
  2. Resolution of Previous S.I. Anomalies: The amendments aim to remove ‘gold-plating’ and clarify definitions, including:
    • ‘Net turnover’ and ‘applicable company’.
    • ‘Applicable branch’ and ‘applicable subsidiary’ of third-country undertakings (non-EU undertakings).
    • Introduction of a new definition for ‘ultimate parent undertaking’.
    • Expansion of subsidiary exemptions, permitting an Irish subsidiary to claim exemption if included in the group Sustainability Statement of an EU parent, prepared in accordance with consolidated sustainability reporting obligations.

For a detailed view of the Statutory Instrument, please refer to the official documentation here.

Other Related Updates

The EU Commission has adopted a Delegated Act “quick fix” on 11 July, addressing two critical areas:

  1. Wave One Reporters: These entities will not be required to report additional information in FY25 and FY26, such as the financial effects of sustainability-related risks.
  2. Phase-In Provisions: Companies with more than 750 employees will benefit from phase-in provisions similar to those currently applicable to smaller companies for the financial years 2025 and 2026.

For further details and access to the Delegated Act, visit the EU Commission webpage here.

Additionally, Deloitte’s July 2025 updated iGAAP in Focus reflects recent Omnibus updates and serves as a valuable reference point for understanding these changes.

For further discussion or inquiries, please contact our team at ieesgauditassur@deloitte.com.

iGAAP in Focus - EU Comission Sustainability Reporting

This ‘iGAAP in Focus’ sets out several pieces of proposed legislation ('omnibus proposal') that were published by the European Commission (EC) on 26 February 2025.

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