CSRD in Ireland: What It Means for Irish SMEs
Introduction
Irish small and medium-sized enterprises (SMEs) keep hearing about the Corporate Sustainability Reporting Directive (CSRD), so here is the direct answer first: since the Omnibus I directive (in force 18 March 2026), no SME reports under CSRD. Mandatory scope is limited to companies with more than 1,000 employees and net turnover above €450 million. If you are unsure which side of the line you sit on, see Is My Company Too Small for CSRD?
What an Irish SME faces instead is the request that trickles down. The large customers, multinationals, and banks that do report under CSRD need data from their value chains, so they ask their Irish suppliers and borrowers for energy, emissions, and workforce information.
The practical way to answer those requests is the Voluntary Sustainability Reporting Standard for SMEs (VSME), developed by EFRAG. This guide explains who actually reports in Ireland, what a data request looks like, and how to answer one without full CSRD complexity.
What is the CSRD?
The Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464) is an EU law requiring companies to report on their environmental, social, and governance (ESG) impacts with the same rigour as financial reporting. It replaces the older Non-Financial Reporting Directive and aims to create transparency and comparability across Europe.
Since Omnibus I, only the largest companies are directly in scope (what the Omnibus changed). Irish SMEs are affected indirectly, because in-scope companies must disclose sustainability data across their value chains: suppliers, subcontractors, and partners.
For a small Irish company, this means you will not report under CSRD yourself, but your customers or bank may request sustainability data aligned with the VSME Standard.
Which Irish Companies Must Report?
After the Omnibus I directive narrowed the scope, the schedule stands as follows:
| Category | Who It Covers | First Reporting Year |
|---|---|---|
| Wave 1: large public-interest entities | Listed companies, banks, and insurers with more than 500 employees | Already reporting (2025, for FY2024) |
| Wave 2: other large companies | More than 1,000 employees and net turnover above €450 million | 2028 (for FY2027) |
| Listed SMEs | Removed from mandatory scope by Omnibus I | No longer required |
| Non-EU companies | More than €450m EU turnover, with an EU subsidiary or a branch above €200m | Around 2029 (for FY2028) |
Almost every Irish SME falls far below these thresholds and will never file. However, if you supply a large company (for example, a multinational in pharma, food, or construction), you may be asked for data on energy, emissions, and workforce metrics.
Those requests now have a legal ceiling. For CSRD purposes, an in-scope customer cannot demand more from a supplier with fewer than 1,000 employees than the VSME Standard covers, which makes one VSME report the practical answer to most questionnaires; see how one VSME report answers every ESG request.
How Irish SMEs Can Use the VSME Standard
The VSME Standard (2024) is published by EFRAG for non-listed micro, small, and medium undertakings. It helps SMEs report sustainability information relevant to their clients, banks, or investors.
Step 1: Choose Your Reporting Module
- Basic Module (B1–B11) – The core disclosures: energy, emissions, water, waste, workforce, and business conduct.
- Comprehensive Module (C1–C9) – Adds datapoints such as climate targets and climate risks for businesses working closely with financial institutions or large clients.
VSME Basic vs Comprehensive Module walks through the choice.
Step 2: Gather Simple Metrics
Start with easily available data such as:
- Energy bills for MWh consumption and Scope 1–2 emissions.
- Waste invoices for recycling and landfill totals.
- Payroll data for gender pay gap and training hours.
- HR or safety records for accident rates.
Step 3: Align with Clients’ Needs
Irish SMEs can use VSME templates to respond to sustainability questionnaires from large buyers. This shows readiness and may strengthen your position in tenders or bank applications.
Tip: If your clients mention ESRS or Scope 3 emissions, these relate to how your data feeds into their own reports. The VSME format is compatible with ESRS data needs.
Ireland’s Local Context
Ireland’s sustainability landscape supports CSRD alignment through several initiatives:
- Sustainable Finance Ireland promotes ESG reporting awareness.
- Enterprise Ireland offers green transition funding and advisory services.
- SEAI (Sustainable Energy Authority of Ireland) provides grants for energy efficiency tracking, and the data gathered for SEAI schemes maps directly to VSME energy disclosures.
Irish law mirrors the EU implementation of CSRD, and nothing in it requires an SME to report. Using the VSME Standard is voluntary; its value is meeting the market expectations of the large clients and banks you deal with.
Frequently Asked Questions
When does CSRD take effect in Ireland?
CSRD took effect across the EU on 5 January 2023, and Ireland transposed it into national law in 2024. Large Irish public-interest entities began reporting in 2025 for FY2024, and other large companies meeting the post-Omnibus threshold (more than 1,000 employees and €450 million turnover) report in 2028 for FY2027. The planned wave for listed SMEs was removed by the Omnibus I directive, so no SME is brought into scope.
See full CSRD deadlines by country →
Are there local Irish resources for sustainability reporting?
Yes. The SEAI, Enterprise Ireland, and Sustainable Finance Ireland provide sector guides, funding options, and training. These align with EU sustainability data requirements and help SMEs start with practical steps.
Do Irish SMEs report in English or Irish?
A VSME report can be in English, which is the working reporting language in Ireland. EFRAG’s free VSME digital template is available in 11 languages, including Irish (added February 2026). You may include bilingual elements for local stakeholders if preferred.
What Irish regulations interact with CSRD?
Ireland transposed CSRD through amendments to company law in 2024, and the reporting duty applies only to in-scope large companies. No Irish law requires an SME to file sustainability information. Data an SME already gathers for energy grants, waste permits, or payroll can usually be reused in a VSME report.
Key Terms
- CSRD – Corporate Sustainability Reporting Directive, the EU law requiring the largest companies (more than 1,000 employees and €450 million turnover since Omnibus I) to publish sustainability disclosures.
- VSME – Voluntary Sustainability Reporting Standard for non-listed SMEs, published by EFRAG. The practical format for answering customer and bank data requests.
- ESRS – European Sustainability Reporting Standards, the detailed disclosure standards used by companies in CSRD scope.
- Omnibus I – The EU simplification directive in force from 18 March 2026. It narrowed CSRD scope, removed the listed-SME wave, and capped value-chain data requests at the VSME level for suppliers with fewer than 1,000 employees.
- Scope 1–3 Emissions – Direct and indirect greenhouse gas emissions categories.
- SEAI – Sustainable Energy Authority of Ireland, national energy agency supporting reporting readiness.
Conclusion & Next Steps
No Irish SME is required to report under CSRD, and the Omnibus I directive made that permanent rather than a delay. What is rising fast is the number of data requests from in-scope customers and banks, and the VSME Standard is the proportionate way to answer them from data you largely already hold.
Start with our guide to understanding CSRD reporting and learn about choosing between VSME Basic and Comprehensive modules. Free VSME report tools now generate a finished Basic Module report at no cost, which is usually enough to answer a first request.
