On 3 July 2026, the European Commission adopted two delegated acts dealing with sustainability reporting. The first, C(2026)5010 final, amends Commission Delegated Regulation (EU) 2023/2772 as regards the simplification of the European Sustainability Reporting Standards (ESRS). The second, C(2026)5011 final, supplements Directive 2013/34/EU by establishing sustainability reporting standards for voluntary use by undertakings protected by the value chain cap. Both delegated acts remain subject to scrutiny by the European Parliament and Council and will not enter into force until publication in the Official Journal.
Revised ESRS: a more focused reporting framework
The revised ESRS form part of the EU’s wider Omnibus I simplification package, reflected in Directive (EU) 2026/470. The Commission’s stated objective is to reduce administrative burden while preserving the quality and usefulness of sustainability disclosures. The standards continue to sit within the Corporate Sustainability Reporting Directive (CSRD) framework and retain the core concept of double materiality. In practical terms, companies must still consider both how sustainability matters affect the business and how the business impacts people and the environment.
The changes are significant. They reduce mandatory datapoints by over 60% and total datapoints by over 70%. The revised standards also seek to give clearer guidance on materiality, with a view to avoiding unnecessary reporting and limiting the risk that assurance processes drive companies to disclose immaterial information.
For in-scope businesses already preparing for ESRS reporting, the revised standards should not be regarded as a reason to pause their efforts. While the regulatory burden may be reduced, the need for reliable data, clear internal ownership and robust governance endures.
The voluntary standard and out-of-scope companies
The voluntary reporting standard is designed primarily for value-chain undertakings with no more than 1,000 employees that are outside mandatory CSRD reporting and are protected by the value chain cap, but still receive sustainability information requests from banks, investors, larger customers and supply-chain partners. The voluntary standard is intended to provide a proportionate and standardised framework for those businesses.
The voluntary standard should help smaller companies respond to recurring ESG questionnaires in a more efficient way and support access to finance, tenders and commercial relationships. It also has an important protective function. Under the value chain cap, in-scope undertakings cannot require protected undertakings to provide sustainability information beyond the information covered by the voluntary standard. Protected undertakings also have a statutory right to refuse information requests that exceed that cap.
This will be particularly relevant for Irish companies operating in European supply chains. A business may be outside mandatory CSRD reporting but may still receive sustainability information requests from lenders, investors, customers or supply-chain partners. Whether it is legally required to respond will depend on the value chain cap, any applicable contractual obligations and the commercial context. Voluntary reporting can therefore be commercially useful. It should, however, be approached carefully. Any statements made should be accurate, evidenced and capable of standing up to scrutiny under consumer protection, the EU green transition rules now in force under Directive (EU) 2024/825, any future Green Claims Directive once adopted and applicable, and competition law principles.
Irish legislative framework
Ireland has already transposed the original CSRD through S.I. No. 336 of 2024, with further technical amendments adopted in 2024 and substantively important timing amendments adopted in 2025. The European Union (Corporate Sustainability Reporting) Regulations 2025, S.I. No. 309 of 2025, gave effect in Ireland to the EU “Stop the Clock” Directive by postponing reporting obligations for Wave 2 and Wave 3 companies while the Omnibus I reforms were being negotiated.
The next step is domestic implementation of Directive (EU) 2026/470, the Omnibus I Directive, insofar as it amends the CSRD. The Directive entered into force on 18 March 2026 and Member States must transpose the CSRD-related amendments by 19 March 2027. In a Dáil written answer on 9 June 2026, the Minister of State at the Department of Enterprise, Tourism and Employment confirmed that the Department is engaged with the Office of the Parliamentary Counsel on a statutory instrument to give effect to the CSRD aspects of Omnibus I. The Minister indicated that the instrument is expected to be signed before the end of 2026, well in advance of the EU deadline.
For Irish businesses, that timing matters. Companies that may fall outside the revised thresholds should monitor the Irish statutory instrument before assuming they are no longer in scope. Companies that remain in scope should use the intervening period to reassess reporting boundaries, data controls, assurance readiness and supply-chain information requests against the revised EU framework. And while the overall direction of travel is towards a narrower and more proportionate regime, this does not imply a lower standard of governance for sustainability information.
For more information, please contact John Gaffney or your usual contact in Beauchamps LLP.
