Regulatory Round-Up – Q4 2025
On a quarterly basis, Business in the Community Ireland shares the latest developments in EU sustainability regulations, highlighting key updates, stakeholder insights, and practical resources.
This quarter, we’ve added a section on the EU Pay Transparency Directive, complementing efforts already underway in Ireland through gender pay gap reporting and action plans since 2022. Reinforcing the principle of equal pay for equal work, the directive aims to increase transparency for employees and job seekers by ensuring access to clear and comprehensive information about pay structures and disparities.
We also continue to monitor developments around the EU Deforestation Regulation and Omnibus, as well as the evolving landscape for CSRD and CSDDD. Various institutions and organisations are providing valuable lessons from the first wave of sustainability statements, helping to shape the next iteration of disclosure and due diligence.
Find out more about the most material updates in this Regulatory Round-Up for Q4 2025 — and as always, we welcome your feedback and topic suggestions for future editions.
Clean Industrial Deal
Business in the Community Ireland joined 130+ businesses, investors and civil society groups in calling for the effective implementation of the Clean Industrial Deal, with a clear message: “Strengthening Europe’s industrial edge: A business roadmap for resilience and competitiveness.”
We see the Clean Industrial Deal as a strategic opportunity for Europe to lead global races for clean innovation and technology — fostering new partnerships, building on the EU’s strong industrial base, and leveraging the potential of its single market.
The statement outlines the following priority actions:
- Ground industrial decarbonisation investment in an ambitious climate target, -90% emissions by 2040.
- Secure EU leadership in clean and circular economy technology.
- Demonstrate that decarbonisation is beneficial, technically and economically viable.
- Close the finance gap — mobilise public finance and leverage private capital.
- Phase out fossil fuels and boost electrification.
- Ensure the transition is fair and inclusive.
Resources:
EU Climate Law
Last year, the EU began developing a 2040 climate target as part of the European Climate Law — an interim milestone towards Net Zero by 2050 and a complement to the 2030 target (-55% GHG reduction).
In 2025, the Commission proposed a 90% reduction in net GHG emissions by 2040 (compared to 1990 levels). Agreement on this target has been delayed several times. In October, Commission President Ursula von der Leyen pledged to adjust key green laws to secure support for a new target.
EU leaders met at the European Council Summit on 23 October, where the 90% figure was not explicitly mentioned in the outcome document. “Enabling conditions” were agreed, with final details expected ahead of the extraordinary Environment Council on 4 November, where ministers will vote on the compromise text.
Resources:
Parliament stalls EU’s first effort to simplify rules for business – Politico (22.10.2025)
Summary of CSRD and CSDDD positions – Frank Bold (15.10.2025)
US and Qatar issue energy and trade threats to EU over climate rules – Financial Times (Oct 2025)
General News and Resources
Omnibus I – The Future of EU ESG Regulations
The Omnibus process continues to evolve, with EU institutions under pressure from Member States and non-EU governments (including the US and Qatar) to weaken elements of the CSRD and abolish the CSDDD.
A tense European Parliament vote decided whether the Omnibus could move to final trilogue negotiations. The result means the text will now be discussed in plenary session on 11–13 November, opening the door to further amendments.
Although outcomes are uncertain, seven key elements merit close attention:
Scope of directives
Double materiality lens
Transition plans
Due diligence obligations and risk-based approach
Value chain cap
Civil liability
Obligations for non-EU companies
Resources:
EU Nature Restoration Law
EU Member States must submit National Restoration Plans by mid-2026, outlining how they’ll deliver targets under the EU Nature Restoration Law.
In Ireland, the National Parks and Wildlife Service (NPWS) is hosting a Leaders’ Forum series to engage key stakeholders, whose input will shape Ireland’s Nature Restoration Plan.
Resources:
GHG Protocol Scope 2 Guidance
The GHG Protocol has launched two 60-day public consultations (closing 19 December):
Updates to Scope 2 Guidance (2015), addressing inventory accounting.
Consequential accounting methods for estimating avoided emissions from electricity-sector actions.
These reviews — the first in a decade — are relevant to large energy users and aim to increase data granularity.
Resources:
Pay Transparency Directive
Background
EU efforts continue to strengthen the principle of equal pay for equal work and address the gender pay gap (currently 13% per hour on average, per Eurostat). The Directive promotes pay transparency, helping employees and job applicants access fair and clear information about pay structures.
Requirements
The Directive introduces:
Disclosure requirements: Annual gender pay gap reporting (250+ employees) or every three years for smaller undertakings (>100 employees).
Access to salary information: Pay ranges in job offers and transparency on pay progression criteria.
Access to justice: Compensation systems and penalties for non-compliance.
In Ireland, annual gender pay gap reporting (introduced in 2022) now applies to all organisations with 50+ employees (from 2025).
Next Steps
Member States must transpose the Directive into national law by 7 June 2026. Reporting obligations begin in 2027, based on 2026 data.
Resources:
Corporate Sustainability Reporting Directive (CSRD)
Frank Bold’s landmark analysis of the first CSRD-compliant sustainability statements found:
Improved readability and accessibility.
Stronger double materiality assessments.
Enhanced understanding of risks, opportunities, and climate transition planning.
These findings align with BITCI’s own position shared with Irish MEPs — supporting effective, widespread implementation to drive better sustainability governance.
Resources:
European Sustainability Reporting Standards (ESRS)
The public consultation on amended ESRS has closed. Feedback is now under review by EFRAG. The French Financial Markets Authority (AMF) has published insights based on first-year CSRD reports, focusing on:
Climate transition plans (ESRS E1)
Own employees (ESRS S1)
Materiality assessments
Minimum disclosure requirements
Interoperability
Resources:
EU Deforestation Regulation (EUDR)
The European Commission proposed measures to ease implementation of the EUDR, including:
Compliance delay for SMEs (to 30 Dec 2026) and grace period for larger companies.
A new “downstream operator” category aligned with trader obligations.
Streamlined due diligence submission — only one per supply chain.
Resources:
Green Claims Directive
Discussions on the Green Claims Directive were paused in June, though the Danish EU Presidency intends to relaunch trilogue negotiations before the end of 2025, aiming for adoption in 2026.
Resources:
Circular Economy and Related Initiatives
Circular Economy Act (CEA)
Feedback on the scope of the upcoming Circular Economy Act (2026) remains open until 6 November 2025.
Circular Economy in Ireland
The Department of Climate, Energy and the Environment is running two public consultations:
Circular Economy Strategy 2026–2028 (closes 5 November).
Review of the WEEE and Batteries Producer Responsibility Schemes (closes 24 November).
Carbon Border Adjustment Mechanism (CBAM)
Importers of carbon-intensive goods into the EU (iron, steel, aluminium, cement, fertiliser, electricity, hydrogen) must register as Authorised CBAM Declarants via the AMM and report emissions quarterly.
Resources:
Other Regulations to Watch
AI Act – No updates this quarter.
European Accessibility Act (EAA) – No updates this quarter.
