Facts checked 25 July 2026. This is general information, not legal advice — scope questions belong with your auditor or advisor, and the amending directive’s final text is the authority.
If you last read about CSRD in 2024 or early 2025, most of what you read is now out of date. The EU’s Omnibus I simplification package, adopted in early 2026, substantially rewrote who has to report and when. A lot of Irish companies that spent 2024 preparing for CSRD are no longer in scope at all.
Here is the current position, in plain terms.
Who actually has to report now
Under the amended rules, CSRD applies to companies with more than 1,000 employees and net turnover above €450 million — dramatically narrower than the original thresholds (250 employees / €50m turnover) that would have caught hundreds of Irish businesses.
Three practical consequences:
- Listed SMEs are out. The original directive would have pulled listed small and mid-caps in from 2027. They have been removed from scope entirely.
- “Wave 2” and “wave 3” companies got a reprieve. Reporting for the newly-defined scope applies for financial years beginning 1 January 2027 — the first reports land in 2028.
- The very largest companies still report. Wave-one companies (the former NFRD population, 500+ employees) that also meet the new thresholds are reporting now; those that fall below them are exempt for FY2025–2026.
If your business is under 1,000 employees, CSRD itself is — for now — not your problem.
Why energy strategy still matters if you’re out of scope
Being outside CSRD does not mean sustainability data stops mattering. Three pressures remain fully in force:
- Supply-chain requests. The companies that do report need emissions data from their suppliers (Scope 3). If you sell to a multinational, a large retailer or a public body, you will keep being asked for energy and emissions figures — CSRD scope or not.
- Banks and investors. Lending decisions increasingly price in energy exposure. A business generating a share of its own electricity presents a measurably lower cost-risk profile.
- The bill itself. Irish commercial electricity remains among the most expensive in Europe. Whatever the reporting rules say, a decades-long hedge against your largest controllable overhead stands on its own numbers.
Where solar fits — honestly
On-site solar gives you the one thing every sustainability request has in common: a real, metered number. A monitored PV system produces auditable kWh-generated and kWh-consumed data, which converts directly into Scope 2 emissions reductions using published grid factors. No estimates, no consultants’ models — meter readings.
For a company still in CSRD scope, that data slots into the climate standard (ESRS E1) as both a consumption figure and evidence of a transition plan being executed. For everyone else, it’s the answer you attach to the customer questionnaire — and a smaller bill either way.
What solar does not do is make a reporting obligation disappear — panels are not a compliance product on their own. It is one concrete, measurable action inside a wider energy strategy — usually the one with the clearest payback.
The sensible sequence
- Establish your baseline — 12 months of bills, annual kWh, unit rates per meter.
- Check what you’re actually being asked for — by customers, lenders or (if in scope) your auditor. Design data collection around real requests, not hypothetical ones.
- Assess the roof — a commercial solar assessment tells you what share of consumption you could self-generate, what the NDMG grant covers, and the payback at your unit rate.
- Meter what you build — monitoring comes as standard on our installations; the reporting value is in the data trail.
The regulatory pendulum has swung toward simplification, but electricity in Ireland has not got cheaper and customers have not stopped asking questions. The businesses that treated energy as strategy rather than compliance are the ones the Omnibus barely affected.
Talk to us about a commercial energy assessment — (090) 640 0180.