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If you last read about CSRD in 2024 or early 2025, most of what you read is now out of date.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.
Who has to report now
Under the amended rules, CSRD applies to companies with more than 1,000 employees and net turnover above €450 million. That is dramatically narrower than the original thresholds (250 employees / €50 million turnover), which 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, so 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 still matters if you’re out of scope
Being outside CSRD doesn’t mean sustainability data stops mattering. Three pressures remain 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 is expensive, typically 25–35c/kWh fully loaded, though contracts vary and commercial tariffs are not published centrally. Irish household prices are the highest in the EU (Eurostat, H2 2025), and the same network and generation costs sit underneath every bill. Whatever the reporting rules say, a decades-long hedge against your largest controllable overhead stands on its own numbers.
Where solar fits
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. The self-consumed share converts directly into Scope 2 reductions using published grid factors. Exported units are accounted for separately and do not reduce your Scope 2 figure on their own. The figures come from meter readings rather than estimates.
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.
Solar doesn’t make a reporting obligation disappear, and panels aren’t a compliance product on their own. What a system gives you 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 being asked for, by customers, lenders or (if in scope) your auditor. Design data collection around real requests rather than 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.
Reporting got simpler for most companies, but electricity in Ireland has not got cheaper and customers have not stopped asking questions. A business that treats energy as a cost it can manage has less riding on where the reporting rules land next.
Talk to us about a commercial energy assessment, or call (090) 640 0180.