Permanent TSB’s Norma Conway tells Accountancy Ireland why neurodiversity must be part of every organisation’s diversity, equity and inclusion strategy Employers who embrace neurodiversity stand to benefit from new ideas and fresh thinking that can boost the bottom line. So says Norma Conway, Diversity and Inclusion, Wellbeing and Engagement Manager with Permanent TSB. As Conway sees it, the neurodivergent community is currently a largely untapped resource for employers in Ireland, many of whom are unaware and unprepared for the strengths and capabilities this cohort can bring to the talent pool. “The benefits of neurodiversity are undeniable. Companies with neurodiversity programmes already in place report improved retention rates, reduced turnover and increased productivity and innovation,” Conways says. In “Neurodiversity as a Competitive Advantage”, an article published in The Harvard Review in 2017, for example, authors Robert D Austin and Gary P Pisanom reported that neurodiverse teams were 30 percent more productive than their neurotypical counterparts. Similarly, a still oft-quoted survey commissioned back in 2003 for the BBC series Mind of a Millionaire found that 40 percent of the UK’s self-made millionaires were dyslexic. Neurodiversity: what it means So, what is neurodiversity? The term was coined in the late nineties by Judy Singer, an Australian sociologist, to recognise that everyone’s brain develops in a unique way.  Harvard Health defines neurodiversity as, “the idea that people experience and interact with the world around them in many different ways; there is no one ‘right’ way of thinking, learning, and behaving, and differences are not viewed as deficits”. While Singer primarily views neurodiversity as a social justice movement, research and education in the area is also increasingly used by clinicians to understand numerous conditions, according to Harvard Health. These conditions range from autism spectrum disorder and attention deficit hyperactivity disorder (ADHD) to dyslexia, dyscalculia and dyspraxia. The upside for business For Conway, the benefits of these different ways of thinking are obvious for employers.  “Neurodivergent people bring a ‘business upside’ literally because they think differently,” she says. “In general, people with dyslexia are better at visual thinking and they are more creative. They have an approach to looking at data and problem-solving that I wouldn’t see myself.  “People with ADHD bring creativity, energy and passion. That’s built into the mindset of how they think and how they approach problems.” For employers, this can mean valuable access to better problem-solving capabilities and a more effective approach to strategising. “In most workplaces, we are generally trying to solve problems, improve things or find solutions, so having someone in the room who thinks differently automatically brings a new approach,” Conway says. “If you’re trying to brainstorm ideas and you bring someone into the mix who thinks differently, is more creative and asks questions nobody else is asking, the power in that is phenomenal.” Understanding and embracing neurodiversity in workplaces, schools and communities can also improve inclusivity for everyone, Conway adds.  “Every human is unique, with a unique combination of abilities and needs. Creating an environment that is helpful to neurodivergent people and that recognises everyone’s individual strengths and talents embraces this idea,” she says.  While she sees growing awareness of neurodiversity in society generally, Conway says the majority of employers continue to adopt a one-size-fits-all approach to recruiting, managing and supporting their employees.  “We have students in Ireland now receiving supports and accommodations throughout school and college, but they reach the workplace and hit immediate barriers as these supports and accommodations don’t exist in most companies,” she says. There is a “huge opportunity” here for employers to access a talent market that is thus far largely untapped, says Conway. The Same Chance Toolkit: A Step by Step Guide to Becoming an Autism Friendly Employer, published earlier this year by AsIAm, Ireland’s national autism charity, revealed that 85 percent of autistic individuals are either unemployed or underemployed.  “This is an opportunity for companies, not only to fill roles, but also to contribute to social justice and employment equity,” says Conway. The Permanent TSB experience As a large organisation employing 3,000 people nationwide, Diversity, Equity and Inclusion (DE&I) first became a key strategic priority for Permanent TSB back in 2017. Neurodiversity has been part of this strategy from day one and continues to evolve in line with developments in the wider world. “The focus on neurodiversity has changed in more recent years and there is an awareness that we need to do more, which has been captured as part of our latest DE&I Strategy for 2023 to 2025,” Conway says. “We now understand the complexities of neurodiversity, how neurodivergent colleagues are impacted by the work environment and the multiple potential business advantages to having diversity of thought in teams.” Ability is one of the main areas of focus in Permanent TSB’s DE&I strategy. “In May, we announced the establishment of our Ability Employee Resource Group (ERG) encompassing both physical ability and neurodiversity. We wanted to hear from colleagues and get their input as we plan to increase awareness and supports,” Conway says. “We’ve worked with the Trinity Centre for People with Intellectual Disabilities (TCPID) for a number of years and more recently we started working with Specialisterne (specialisterne.ie) and AsIAm (asiam.ie) to help understand what a positive experience should look like for candidates and colleagues when hiring neurodiverse talent.  “We have taken their advice on how we can improve our existing processes, onboarding and training and they have also helped us to understand accommodations that may be needed.”  AsIAm is currently working with Permanent TSB’s Digital and Direct Office teams on a sensory review of the banks’ premises and facilitating training for managers.  “It’s important that managers have a core understanding of the realities of neurodiversity and have the strategies needed to respond and take action,” Conway explains.  “Our first Ability ERG workshop will be facilitated in October by the Irish Centre for Diversity and, from there, we will have a clear plan of action based on our colleagues’ feedback and their needs.” Best practice advice for employers Based on her own experience with Permanent TSB, Conway’s advice for other employers is that supporting the needs of employees who are neurodivergent starts right at the beginning of the employment relationship – the recruitment stage. “Standard recruitment practices can be a barrier. Aptitude tests or complex job descriptions and formal interview processes can be challenging – so working with external experts who can advise on any adjustments needed has been a big help for our team,” she says.  Accommodations should be considered relative to the built environment, communications and sensory supports.  “Simple adjustments, such as the lightbulbs we use, or having a decompression room available away from the open-plan office space if needed, can make a difference,” Conway says. “We’re also in the process of rolling out Microsoft 365 and a team of neurodiverse colleagues and allies have worked with IT to ensure that all accessibility features are switched on for all colleagues.  “To complement this, we aim to introduce a support toolkit to include, for example, noise-cancelling headphones and screen readers colleagues can order online.”    Also key to supporting employees who are neurodivergent is buy-in and input right from the top of the organisation. “The support of our own leadership at Permanent TSB has been very important for us,” Conway explains. “It’s great to try to start initiatives and broaden communications and training but without their support – and a willingness to be visible in their support – it would be very challenging.” Start today: first steps  So, what are the first steps employers can take now to begin implementing a workforce strategy that encompasses neurodiversity? “First, listen to the experts,” Conway says. “There are many organisations out there that understand the complexities and supports needed that can guide you – they have the answers so ask for advice as you map out a plan.”  Second, listen to your employees. “Most people now have a personal interest in making the workplace more neurodiverse inclusive, whether it’s from their own perspective, a family member’s or a friend’s,” Conway says.  “Listening to these employees, encouraging them to share their stories and helping them shape your strategy will build trust that is invaluable.”    Ultimately, implementing a workforce strategy that accommodates neurodiversity benefits everyone, Conway says: “It has a knock-on effect on how we interact with each other, our openness with each other, and comfort in sharing information. It is well worth the effort.” Written by Tess Tattersall and Elaine O’Regan  

Julia Rowan answers your management, leadership and team development questions I work in HR and recently helped a partner recruit a manager to lead a team of six people. The team had been without a manager for about a year and there are issues which need tackling. We wrote a very specific job description which highlighted the people management aspect of the role and focused on this a lot at the interview. The new manager has not stepped up to the people management aspect of the role; they say that they don’t have the time as there is too much work. The partner has asked me to intervene – but the new manager is very defensive.  Managing people is wonderful. It is also tough, and it can be much easier for managers at all levels to focus on the work than on the people.  In many organisations, there is a lot of aspirational talk about people/culture that does not translate into the lived experience of employees. So, sometimes people ‘talk the talk’ to get a role and then step back when faced with a challenge.. I love that you paid so much attention to the job description and interview – you laid a solid foundation for future conversations.  When the new manager came on board, did the partner sit down with them and draw a red thread between the interview and the role, explaining why they were given the role? This type of conversation builds on the foundation and provides real clarity about desired behaviours. It is not too late to do this, and probably very important that it happens. The partner has asked you to intervene – is this due to lack of time, misperception of HR’s role or avoidance of the issue? Certainly, you can help, but this is a great opportunity for the partner to role model how to step into leadership and deal with a tough issue.  I think your first call is to explore how the partner is supporting their new manager. Do they have regular one-on-one meetings? If so, are they all ‘business’, or are they talking about the people issues too? If the partner cannot offer support, at the very least they need to let the new manager know that you are acting on their behalf and they need to stay involved. You and/or the partner may need to have a few meetings with the new manager to explore what is happening, build trust around the issue and ensure that they are bought in.  You will need to ‘listen like crazy’ without explaining or advising so that you can get to the heart of the matter.  Ask them what support they need to tackle the situation. Make sure they are connected to other people managers across the organisation who may be able to support them. Let us not forget that there are legacy issues at play here, and perhaps the ‘ask’ of the new manager is too big. A well-run team session could help the team to disentangle issues and move on. But these issues can run deep, and professional help may be needed. Julia Rowan is Principal Consultant at Performance Matters Ltd, a leadership and team development consultancy. To send a question to Julia, email julia@performancematters.ie

Three Chartered Accountants share their perspectives on the changing role of the Chief Financial Officer in today’s fast-paced business, regulatory and societal environment Johnny Harte Founder True Fund Solutions  The Chief Financial Officer (CFO) in a company has long been considered the chief bean-counter whose job has been to say ‘no’ more than ‘yes’.  And in the past, this has been true. CFOs today still have responsibility for the core finance function in an organisation, but they are now increasingly regarded by management and key stakeholders as value-creation partners in a business, and their expanding role reflects this. As a starting point, to realise more efficiencies, CFOs are now investing more in technologies to assist the finance team. Transactional activities are being replaced by artificial intelligence and machine learning technologies, and the way in which financial information is being presented, shared and consumed has changed in line with the expectations of end-users. The CFO may have responsibilities outside the core finance function, too, like human resources and IT, so collaborating with many other departments in the business is more important than ever.  New initiatives to address issues such as environmental, social and governance (ESG) concerns fall under the remit of the CFO as well.  As an example, the financial implications and reporting obligations of ESG are felt company-wide, but they ultimately feed into the finance function. Companies find themselves in times of rapid change that offer potential opportunities, like product innovation, access to new markets, and even the development of new business models. Change can also result in potential risks such as cyber security, geopolitical and environmental concerns, however.  CFOs, by necessity, find themselves at the heart of all of this and play a vital role in navigating the landscape and advising on strategic decisions that can shape the future of the business. CFOs are in a unique position in a company in so far as everything that is important eventually gets reflected in numbers. The old line of “you can’t manage what you can’t measure” still holds true. Karen Sugrue Hennessy  Sustainability Consultant and CEO Real Leaf Farm As our nation, along with the rest of the world, faces mounting pressure to fulfil its climate change commitments, Chief Financial Officers (CFOs) are stepping into a critical leadership role.  According to the Environmental Protection Agency (EPA), Ireland is currently on track to achieve just 29 percent of its committed 51 percent net zero target by 2030. Finance stands as a pivotal enabler in the acceleration of climate action, as emphasised by the Intergovernmental Panel on Climate Change report (AR6).  CFOs, accountants, bankers and directors are primed to lead the charge by shifting their focus away from financing environmentally detrimental projects and redirecting their efforts toward funding initiatives that bolster the transition to a sustainable economic model. By 2029, all businesses, including SMEs, will be mandated to enhance transparency and accountability concerning corporate sustainability, operating under the Corporate Sustainability Reporting Directive.  Significant challenges lie ahead, however. Recent research conducted by LinkedIn revealed that close to 95 percent of financial professionals in 48 countries, including major European nations, lack essential green skills.  Shockingly, Ireland ranks at the lowest end of the spectrum in Europe, with just 0.16 percent of finance job postings related to green skills, according to LinkedIn data. So, where should CFOs begin their journey to upskill in this pivotal area, which is undeniably becoming a sought-after area of expertise?  An excellent starting point is joining Chapter Zero Ireland – a collaborative initiative between Chartered Accountants Ireland, IBEC and the Institute of Directors.  Chapter Zero’s primary purpose is to ensure that companies are well prepared for the future and that global net-zero aspirations translate into robust plans and measurable actions.  The evolving role of CFOs in Ireland is not merely a response to regulatory demands; it represents a unique opportunity for financial leaders to champion a more sustainable and responsible future for both their businesses and the nation.  Embracing this transformation is not only a strategic imperative but a moral obligation that can reshape Ireland’s path toward a greener, more prosperous future. Mark Mulqueen CFO KPMG Ireland Like other C-suite roles, the Chief Financial Officer (CFO) role has evolved significantly, reflecting the evolving landscape of business, technology, regulation, global markets and shifting expectations from internal and external stakeholders.  In addition to the traditional CFO responsibilities as financial ‘gatekeeper’, the role has broadened beyond core topics to become more like that of a strategic partner. At the centre of this evolution is a business appetite for greater insights, data-driven commercial partnering, and a more significant focus on profitability and an organisation’s need to transform operating models and core supporting technology.  Consequently, CFOs must keep up to date with the changing landscape of data, technology, taxation and compliance while also managing the organisation’s financial health. As business models continue to transform, looking to the future, this presents opportunities and challenges for CFOs. The value of data – going beyond traditional finance data to provide valuable insights to enhance forward-focused decision-making. Embrace the challenges of data – overcoming disparate systems with multiple data sources to ensure reliability and accuracy is critical to the role. Automation – managing the changing role of technology and staff in traditional finance processes. Talent retention and acquisition – with a broader set of new challenges, it is essential to have the right skills in the team to leverage the opportunity presented by data and technology. Risk – managing risks posed by fraud and cybercrime. Expectation gap – managing the strategic role of the CFO versus the volume of traditional finance work. Leveraging technology, adding new skills to finance teams, and managing this change will allow CFOs to help companies become more agile and responsive to market changes.  The result will provide more value through greater insights on a broader range of topics and the ability to support faster data-driven decisions through automation and technology while simultaneously supporting business change and managing new risks posed by regulation toward sustainable, profitable growth.  The one constant that will remain for CFOs is change.

Ireland’s true gender pay gap will only emerge when SMEs begin reporting and now is the time for this crucial business cohort to start preparing, writes Padraic Hayes Dr BJ Fogg, a renowned behaviour scientist at Stanford University, postulates in his book Tiny Habits that small but frequent incremental changes are often the safest and most effective approach to delivering extraordinary results. One hopes this hypothesis will ring true for the SME sector when it comes to preparing for gender pay gap reporting.  The first gender pay gap reporting obligation came into force in 2022 for companies with over 250 employees.  This will extend to SMEs with over 150 employees next year and even further in 2025 when companies with over 50 employees will also be obligated to commence reporting their first gender pay gap. These milestones are very significant when you consider that, according to the most recent Central Statistics Office figures, SMEs with fewer than 250 employees make up 99.8 percent of active enterprises in Ireland and employ 68.4 percent of the workforce. Gender pay gap reporting thus far has only covered the other one percent of Irish enterprises. We can therefore infer that we have yet to see Ireland’s true gender pay gap figure.  As a result, SMEs are going to be in the full glare of both industry and the media once their first reports are published in 2024. This could be Ireland’s de-facto ‘silver bullet’ solution to truly move the needle on the gender pay gap.  What is the gender pay gap? There continues to be a lot of confusion surrounding what exactly the gender pay gap is. It is defined as the difference between the average hourly wage of men and women in the workplace.  The gender pay gap is an assessment of the gender representation of men and women at each level of an organisation characterised by the overall difference in their pay.  For example, how many males and females are in the top quartile of an organisation’s earners versus the lowest quartile – i.e. how well-represented are females by comparison to males?  It is important that the gender pay gap is not confused with “equal pay for equal work”, which is already a legal obligation for employers in Ireland.  The gender pay gap can be caused by a variety of factors such as unconscious bias, company policies or the division of caring responsibilities in the home. According to the United Nations, women worldwide earn 77 cents for every dollar earned by men.  This suggests that over their lifetime, women’s earning potential is significantly less, a staggering realisation in the modern age.  In Ireland, the gap stands at 11.3 percent, which is slightly more favourable than the EU average of 13 percent (Eurostat). This still equates to about one month a year when a woman essentially works for free. It is important to point out also that this is not just a ‘female’ issue, but an economic issue that affects us all. The reduced earning potential for females affects the overall household income.  It is common for women to find it more cost-effective to stay at home to offset childcare costs, for example, and this places downward pressure on household income in an escalating cost-of-living crisis, and thus the cycle repeats.  For this reason alone, we should all feel motivated to proactively figure out the root cause of this socio-economic issue and break the chain once and for all.  Who needs to report and when? Currently, the obligation to report remains solely on organisations with over 250 employees. The first gender pay gap reports were published in December 2022 and the second are due in December 2023. Next year, however, the obligation will extend to all employers with more than 150 employees. The employers will pick a ‘snapshot’ date in June 2024 and report their gender pay gap metrics for the previous 12 months.  Crucially, the employer will also be required to provide the underlying reason why the gender pay gap exists and, more importantly, what actions they are planning to take to rectify it.  Furthermore, they will need to publicly publish their report either on their website or on the government portal planned for introduction later this year.  As SMEs look ahead to this new landmark reporting requirement, they will be taking the steps needed to ensure they meet these first-time obligations. Here is my advice on the steps you should take and the pitfalls you will need to avoid. Challenges for SMEs  Data collection from disparate systems The gender pay gap report will require inputs from a range of data sources. It is rare for any organisation, no matter what size, to be in a position to extract the data they need from a single source. Finance, payroll and HR systems are disparate in nature and contain data of differing quality. This challenge is amplified where spreadsheets persist in place of systems as the book of record. It can be time-consuming and challenging for non-technical users to extract, organise combine and compare this data and significant effort may be required to cleanse existing datasets in preparation for reporting.  Resourcing The amount of time and effort required to complete the gender pay gap report will be significant – it should not be underestimated. For SMEs, this could prove especially challenging because they are more likely to need to divert attention away from regular activities in situations where there is no dedicated reporting team. This may be especially challenging for the leadership team, who will be required to input into the report and sign it off. All of this increases the risk of introducing ‘bias’, akin to someone correcting their own homework so to speak, which you should avoid at all costs. Availability of expertise  Smaller organisations are highly unlikely to have access to the broad range of expertise needed to complete the gender pay gap report. To create a detailed report requires independent expert skills from a range of disciplines such as data analytics, visualisation and organisational change specialists.  Navigating legislative nuances The guidance in relation to how to report has evolved since the initial introduction of gender pay gap reporting. While many issues have been ironed out through the FAQs available on the government website (gov.ie), there are still nuances in the preparation of the report. My advice is to carefully study the available guidance to ensure you are compliant.  Comparing results While many organisations will be tempted to compare and contrast how they ‘measure up’ against their peers, it is worth bearing in mind that there is no right or wrong answer per se. The gender pay gap is a broad, multifaceted and pervasive issue that goes far beyond the numbers. Focus instead on assessing and improving the aspects of your own company practices, policies and culture that influence the gender pay gap – and your gender pay gap result will follow.  Best practice recommendations for SMEs Fail to prepare, prepare to fail It is important to be prepared for the questions you may get from your employees once your gender pay gap report is published. It is critical that you communicate the result of the report and ensure they fully understand what the data is saying and, more importantly, what it is not saying. It is very common for people to misunderstand the metrics contained in the gender pay gap report. As they say, good news travels fast, but bad news travels twice as fast – lead the narrative. Action planning In your final report, you need to provide a list of actions that you are going to follow to improve your gender pay gap in the 12 months ahead. Set goals for the next year in your report using the SMART (Specific, Measurable, Attainable, Relevant and Time-Bound) technique. It is worth noting again here the importance of focusing on your company practices, policies and culture – and take advantage of the opportunity for a yearly reset. Remember, “what gets measured gets done”.   Get help early on I cannot overstate this enough: get help early on. The requirements of your gender pay gap report may look straightforward at the outset, but do not be fooled.  Preparing such a report can be a time-consuming and intricate process requiring expertise in both data analytics and visualisation and organisational psychology, which together provide a complete assessment.  Moreover, significant input from departments and teams across the organisation will also be needed – typically human resources, finance and payroll, and senior management.  Final word Numerous organisations have come to us seeking help having realised just how complex preparing a gender pay gap report can be.  The best approach is to view it as an in-depth reporting process akin to an annual audit of your workforce analytics, practices, policies and culture.  Padraic Hayes is an Associate Director on Grant Thornton’s digital transformation advisory team and heads the firm’s gender pay gap service offering

First impressions suggest that identifying the Irish companies required to comply with the CSRD will be a straightforward process, but first impressions can be deceptive, writes Fiona Hackett The European Union (EU)’s Corporate Sustainability Reporting Directive (CSRD) was published in its Official Journal in December 2022.   The CSRD replaces the Non-Financial Reporting Directive (NFRD), which in Ireland was applied by companies with more than 500 employees that are public limited companies or regulated by the Central Bank of Ireland. The Irish Government is currently working on the amendments to the Companies Act 2014 that will enact the requirements of the CSRD in Ireland. It is required that these amendments be reflected in Irish law by 6 July 2024. GAAP for sustainability reporting Once enacted in Ireland, the CSRD will require a significant number of Irish companies to prepare a sustainability report subject to assurance by a third party. The sustainability report will need to comply with the suite of 12 European Sustainability Reporting Standards (ESRSs) issued by the European Financial Reporting Advisory Group (EFRAG). These 12 ESRSs have been directly written into EU law and are effectively GAAP for sustainability reporting, covering general sustainability requirements and topical matters under the ‘E’ (Environmental), ‘S’ (Social) and ‘G’ (Governance) pillars.   The ESRSs run to over 350 pages and EFRAG has estimated that there are over 1,000 quantitative and qualitative data points necessary to comply with the more than 80 disclosure requirements of the ESRSs. The CSRD and companies in Ireland The EU has estimated that the number of companies across the EU that will apply CSRD requirements is about 50,000 as opposed to the roughly 11,000 companies that apply NFRD – almost a five-fold increase. However, I would argue that due to the large number of Irish special purposes vehicles, the large population of Irish regulated entities and the popularity of Ireland as the location for intermediate holding companies in large multinational groups, there will be a greater than five-fold increase in the number of companies impacted by the CSRD in Ireland compared with those complying with the NFRD. First impressions of the CSRD suggest that identifying the Irish companies that will be required to prepare a sustainability report and comply with ESRSs is straightforward.   At its simplest, for financial years starting on or after 1 January 2025, large companies, for the purposes of the Companies Act 2014, will be required to prepare a sustainability report that complies with the ESRSs (with some of our large listed companies reporting from 1 January 2024).  We all know that first impressions can often be misleading, however. Identification of what entities will be required to prepare a sustainability report and comply with the ESRSs requires careful consideration and analysis of the type of entity, and – if the entity is a subsidiary company – how the group structure impacts on the preparation of a sustainability report that complies with the ESRSs. Why is type of entity relevant? At present, the Irish enactment of the CSRD is focusing on companies incorporated under the Companies Act 2014.   The Department of Enterprise, Trade and Employment (DETE) indicated in a July webinar that it intends to exempt credit unions and friendly societies from the requirements of CSRD.   Future developments in sustainability reporting and later government policy decisions may see such entities, not subject to the Companies Act 2014, required to prepare sustainability reports that comply with the ESRSs.  The DETE webinar also indicated that not-for-profit companies (often incorporated as companies limited by guarantee) are not in scope of CSRD. They may consider voluntary adoption of the requirements, however.   What should subsidiaries consider? For companies that are subsidiaries, the wider group impact of the CSRD needs to be considered and understood. Whether the subsidiary has a parent in the EU or outside the EU will be crucial in determining the level of sustainability reporting required by the subsidiary. For a large company that is a subsidiary of an EU parent company, it is likely that the EU parent company will be required to prepare a consolidated sustainability report that complies with the ESRSs.   This consolidated sustainability report of the EU parent should include the activities of the Irish subsidiary. It is likely the Irish company will be required to report sustainability information to its parent for inclusion in the consolidated sustainability report.   Such an Irish subsidiary, included in the consolidated sustainability report of an EU parent that complies with the ESRSs, will likely be able to avail of an exemption from preparing its own sustainability report, unless it has debt or equity listed on an EU regulated market. This will be a welcome relief for such companies. On the other hand, in the case of a large company that is a subsidiary of a non-EU parent company, the non-EU parent company is very unlikely to be preparing a consolidated sustainability report that includes the Irish company and complies with the ESRSs.  The large subsidiary company will, therefore, be required to prepare its own sustainability report and comply with the ESRSs in this report.   If this large subsidiary of a non-EU parent company has its own subsidiaries, its sustainability report will be a consolidated report for the group of companies it controls.   It is important to understand that the exemption regime for preparing consolidated financial statements differs from the exemption regime for preparing consolidated sustainability reports.   In Ireland, I expect we will see many intermediate parent companies that have never prepared consolidated financial statements – such as intermediate holding companies that are ultimately subsidiaries of parents in the UK or US – being required to prepare consolidated sustainability reports that comply with the ESRSs when the CSRD becomes effective.   The preparation of a sustainability report that complies with the ESRSs is a significant challenge for a single entity, a bigger challenge for a group of companies and, arguably, an even bigger challenge for an intermediate parent company that has previously never prepared consolidated financial statements, and which does not have an established system or procedures of gathering information for consolidation purposes. Independent exemption regime The exemption regime for companies with respect to preparing a sustainability report that complies with the ESRSs operates independently of the exemption regime for preparing consolidated financial statements.   This appears to be a conscious policy decision made by the EU in developing the CSRD and has been acknowledged in paragraph 26 of the preamble to the CSRD which states: “It should be specified, however, that the exemption regime for consolidated financial statements and consolidated management reports operates independently from the exemption regime for consolidated sustainability reporting. An undertaking can therefore be exempted from consolidated financial reporting requirements but not from consolidated sustainability reporting requirements where its ultimate parent undertaking prepares consolidated financial statements and consolidated management reports in accordance with Union law, or in accordance with equivalent requirements if the undertaking is established in a third country, but does not carry out consolidated sustainability reporting in accordance with Union law, or in accordance with equivalent requirements if the undertaking is established in a third country.” I believe this policy decision demonstrates the importance the EU has placed on sustainability reporting, and both its efforts to be at the forefront of top-quality sustainability reporting and expectation that sustainability reporting will play its part in helping users of annual reports evaluate the sustainability performance of EU companies. The policy decision is also an example of how the CSRD forms part of the European green deal. What action should companies now take? For some Irish companies, there won’t be a lot of complexity involved in understanding whether they are required to prepare a sustainability report that complies with the ESRSs.   We know that an Irish company that has debt or equity listed on the main market of Euronext Dublin and more than 500 employees will have to prepare a sustainability report that complies with the ESRSs for financial years beginning on or after 1 January 2024.   We also know that a large Irish private company that is a standalone company or the ultimate parent company of a large group will be required to prepare a sustainability report that complies with the ESRSs for financial years beginning on or after 1 January 2025.   On the other hand, we also know that a small or medium Irish company will not be required to prepare a sustainability report that complies with the ESRSs while it remains small or medium.  For other Irish companies, the impact of the CSRD is perhaps not as clear-cut. These companies should discuss the requirements of the CSRD with their professional advisors and auditors.   If an Irish company is part of a large multinational group, that company should engage with other parts of the group to understand what work is being done in relation to the adoption of the CSRD and whether there will be exemptions available to the Irish company. Fiona Hackett is Director of Corporate Reporting Services at PwC Ireland and Chair of Chartered Accountants Ireland’s Financial Reporting Technical Committee

It is hard to see how the EU can become a major global player without embracing the reform that would lead to greater integration, says Judy Dempsey The European Union is not in good shape.  There is no agreement over migration or refugees, two issues raised more than two decades ago. The longer member states delay reforming the entire migration and asylum system, the greater the opportunity for anti-immigration and xenophobic parties to capitalise on these delays.  Current trends show that support for the far-right in France, Germany and Poland is increasing in the polls. Instead of co-opting some far-right policies, mainstream parties across Europe need to confront their rising prominence sooner rather than later.  Then there is the unending dispute over how to tackle climate change. This is linked to a radical overhaul of the energy infrastructure across the EU.  Germany and France are at loggerheads about the future of nuclear energy. Germany’s Green coalition party wants to end nuclear energy once and for all, while Berlin has plans to subsidise industry, both of which will delay the country’s transition to renewable energy.  France wants to expand nuclear power for environmental reasons, and Poland is grappling with its coal industry.  Other countries are making the costly and challenging transition to renewable energy sources. This is just the tip of the iceberg.  Eurozone countries cannot agree on further integration of the capital markets and banking system to deepen economic integration.  Take a look at the conflict between the EU Commission and Poland, Hungary and Slovakia. In September, these countries banned Ukrainian grain imports to Europe, going against the European Commission’s authority over trade matters.  As a result, it appears that Member States now hold more power than the commission itself.  It is difficult to see how the EU can become a major global player without embracing the reform that would lead to greater integration – or, at the very least, a bloc that will be more manageable when it expands to incorporate Moldova, Ukraine and the Western Balkans. Enlargement, Russia’s war against Ukraine, the uncertainty of the transatlantic relationship, the results of the 2024 US presidential election, and the rising power of China are all issues that affect Europe’s future.  A new Franco-German paper, put together by a working group of experts and released on 19 September, proposes ideas for making the EU more manageable and governable against a backdrop of pessimism. Based on the premise that there is no agreement on changing the EU treaty – which requires unanimity and, in most cases, a vote from the national parliaments (remember the Nice Treaty vote?) – the paper proposes the following: First, that a coalition of countries move ahead with a “supplementary reform treaty” and, second, that the EU be reorganised around four concentric circles consisting of: the inner circle (presumably eurozone countries);  the rest of the EU;  associate members (Ukraine, Moldova and the Western Balkans); and  the European Political Community (a loose association of European leaders that meet regularly). Given the current state of the Franco-German relationship and its impact on EU integration, it seems unlikely that this paper will be accepted.  Additionally, there are concerns about the democratic legitimacy of the EU and the accountability of its institutions. While the EU parliament has gained some influence, many citizens feel disconnected from the process.  In the face of continued uncertainty, now is the time for smaller and medium-sized countries to propose their plans for the future functioning and sustainability of the EU. Judy Dempsey is a Non-Resident Senior Fellow at Carnegie Europe and Editor-in-Chief of Strategic Europe