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If you last read about CSRD in 2024 or early 2025, most of it is now out of date. The EU’s Omnibus I simplification package, adopted in early 2026, 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 far narrower than the original thresholds (250 employees / €50 million turnover), which would have caught hundreds of Irish businesses.
What that means in practice:
- 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 has fewer than 1,000 employees, CSRD itself doesn’t apply to you for now.
Why energy still matters if you’re out of scope
Being outside CSRD doesn’t mean nobody will ask about your energy use. The pressure still comes from three places:
- 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. Lenders increasingly take energy costs into account. A business generating a share of its own electricity is less exposed to price rises, and that can be shown in the figures.
- 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, first half of 2026), and the same network and generation costs sit underneath every bill. Whatever the reporting rules say, cutting what you pay for your largest controllable overhead for decades makes sense on the numbers alone.
Where solar fits
Every sustainability request wants numbers, and on-site solar gives you real, metered ones. A monitored PV system records auditable figures for kWh generated and kWh consumed, taken from meter readings, not estimates. The share you use on site 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.
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 what you attach to the customer questionnaire. Either way, the bill is smaller.
Panels won’t take care of a reporting obligation by themselves. They are one concrete, measurable step in a wider energy plan, and 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. Collect the data people are actually asking for.
- 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, and that data is what you report from.
Reporting got simpler for most companies. Electricity in Ireland hasn’t got cheaper, though, and customers are still asking questions. A business that manages its energy costs has less riding on where the reporting rules land next.
Talk to us about a commercial energy assessment, or call (090) 640 0180.