Sustainability Reporting & ESG

CSRD: Revised ESRS and voluntary standard

Two key instruments under the Corporate Sustainability Reporting Directive (CSRD) have been published in the Official Journal: the Revised ESRS and a new Voluntary Standard for undertakings outside mandatory CSRD scope.

The Revised ESRS enter into force on 10 November 2026 and apply to financial years beginning on or after 1 January 2027 (i.e. reports published in 2028). Undertakings already reporting on financial years beginning in 2026 (reports published in 2027) have a choice: they may apply the existing ESRS framework (with certain Revised ESRS reliefs available) or adopt the Revised ESRS early.

The Voluntary Standard entered into force on 24 September 2026. It is designed to help smaller undertakings respond consistently to sustainability information requests from CSRD-reporting undertakings, lenders and investors. It also caps the information that larger companies can request from their value chain suppliers.

For more, please see our briefing: CSRD simplification takes shape: Revised ESRS and voluntary standard published.

EFRAG has also advanced three related workstreams:

Datapoints: EFRAG has released the 2026 draft list of datapoints for the Revised ESRS, with comments due by 23 October 2026 and the final resource expected by the end of 2026.
XBRL Taxonomy: EFRAG is consulting on its draft XBRL taxonomy for the Revised ESRS, which will support machine-readable reporting and is aligned with the draft List of Datapoints mentioned above. The consultation closes on 11 November 2026, with final submission to ESMA and the European Commission expected by year-end.
Guidance: EFRAG has published updated non-mandatory guidance relating to the Voluntary Standard.

CSRD: irish Transposition of Omnibus I Directive

The Department of Enterprise, Tourism and Employment has confirmed its intention to transpose the Omnibus I Directive amendments to CSRD by the end of 2026. Member States must transpose these changes by 19 March 2027.

EUDR

The Deforestation and Forest Degradation Bill 2026 is listed for priority drafting in the Government’s Autumn 2026 Legislation Programme. The Bill will give further effect to the EU Deforestation Regulation (EUDR) in Ireland. The EUDR introduces supply chain due diligence obligations for “relevant commodities” (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and specified derived “relevant products” and applies from 30 December 2026 for large and medium operators and traders, as well as micro and small operators and traders from the timber sector. For more, see our briefing: Ireland advances supply chain due diligence legislation.

The Delegated Act which amends the product scope of the EUDR was published in the Official Journal and entered into force on 18 September 2026. The Delegated Act:

updates the list of products derived from EUDR commodities, removing certain cattle, rubber, tyre, soybean, conveyor and transmission belts and vehicle-seat products and adding soluble coffee, certain palm oil derivatives, frozen cattle tongues and certain soaps. The newly added products will apply from 30 December 2027;
excludes samples and products used for analysis, examination or testing; and
exempts specified products, including waste, used goods, packaging and products used to manufacture medicines.

The European Commission recently published updated guidance on the EUDR Information System (the central registry for due diligence statements and simplified declarations submitted under the EUDR) and an infographic to help businesses understand whether and how the EUDR applies to them.

ESAP

ESMA has further postponed the collection of European Single Access Point (ESAP) metadata under the Prospectus Regulation until mid-Q1 2027 (it had previously been deferred until 15 October 2026).

By way of reminder, since 10 July 2026, Officially Appointed Mechanisms and National Competent Authorities have been providing, to the ESAP, information and metadata collected from entities. This is the first phase in the implementation of the ESAP platform which will provide access to financial and sustainability information about entities and their products. The platform will become accessible to the public by July 2027. Information in scope of the first phase of ESAP includes information relating to the Transparency Directive and the Prospectus Regulation.

GREEN TRANSITION DIRECTIVE

The Irish regulations transposing the EU Green Transition Directive took effect on 27 September 2026. There is no formal grace period for products already carrying environmental claims or sustainability labels. EU enforcement authorities have indicated they may take a phased approach in practice, considering factors such as packaging cycles and product shelf-life. However, businesses selling into the EU should be able to demonstrate active steps to bring their claims into line, for example, updating online claims, packaging and new orders.

More details on the Green Transition Directive and its application to the financial services sector are covered in our briefing: The Green Transition Directive: Financial services impact.