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Legal developments shaping Ireland’s agri-food sector for 2026

09/01/2026

Briefing

Ireland’s agri-food sector is entering a period of regulatory change, with new compliance requirements and evolving EU policy shaping considerations for businesses operating across the supply chain. This briefing provides an overview of the latest Irish and EU legal and regulatory developments in the agri-food sector, with a view to identifying relevant developments for businesses active in this sector for the year ahead. We look at:

New powers compelling the provision of information to the Agri-Food Regulator
The European Commission’s recent report on the evaluation of the Unfair Trading Practices Directive
The status of the proposed EU Regulation on cross-border enforcement against unfair trading practices
The Food and Feed Simplification Package announced on 16 December 2025

Agri-Food Regulator to be granted enhanced powers

An Rialálaí Agraibhia (the “Agri-Food Regulator”) was established in December 2023 under the Agricultural and Food Supply Chain Act 2023 (“the Act”) with the statutory remit of promoting fairness and transparency in business-to-business relationships within the agri-food supply chain. The Agri-Food Regulator’s main responsibilities are to ensure compliance with and enforcement of unfair trading law and to provide information on the agri-food supply chain through stakeholder engagement and the analysis of price and market data.

In an important development for those operating in this space, on 16 December 2025, the Minister for Agriculture, Food and the Marine (the “Minister”) announced additional powers for the Agri-Food Regulator in relation to its price and market analysis function. These additional powers are set out in the Agri-Food (Price and Marketing Information) Regulations 2025 (the “2025 Regulations”), which were published on 30 December 2025 and will come into operation on 31 December 2026.

Additional powers

The 2025 Regulations confer enhanced powers on the Agri-Food Regulator to compel the provision of price and market information from businesses in circumstances where voluntary requests for such information have not been complied with. Under the Act, the Agri-Food Regulator must regularly publish reports on price and market data relating to the agricultural and food supply chain, and generally in relation to the agricultural and food sector in the State. To fulfil this function, the Agri-Food Regulator may seek data from businesses relevant to price and margins, including but not limited to:

prices paid and received
margins
financial and accounting data
throughput of agricultural produce
policy and procedural data
employment status and salary information

The Agri-Food Regulator currently carries out its market analysis and reporting functions using publicly available information and data provided voluntarily by businesses. Under the 2025 Regulations, the Agri-Food Regulator will have the power to compel the provision of price and market information from businesses where requests for information have not been complied with voluntarily. The Regulator can only compel information if it issues a formal information notice specifying the data required, allows a reasonable response period and undertakes to consult the business before publishing any information received.

In assessing whether to compel information, the Agri-Food Regulator must consider, amongst other things, the commercial sensitivity of the data requested, and businesses may need to evaluate and make submissions as to commercial sensitivity when responding. The information requested by the Agri-Food Regulator must be required for either analysis of an agricultural and food sector or an agricultural and food product and excludes future price and margin data. Failure to comply with an information notice or providing false or misleading data is an offence under the 2025 Regulations.

Proportionality

The 2025 Regulations will exclude small businesses in recognition of the potential administrative burden these new powers may create. In this context, a small business is defined as an enterprise that employs fewer than 50 persons and whose annual turnover and/or annual balance sheet total does not exceed €10 million.

In addition, and again with a view to minimising potential administrative burdens, the 2025 Regulations provide that the Agri-Food Regulator may not compel data for an individual product from any business more than once in a 12-month period.

Next steps

Given that the 2025 Regulations are applicable at the end of 2026, businesses should start preparing internal systems to ensure they can respond promptly to compulsory requests for information when these take effect. The Agri-Food Regulator will continue to carry out its market analysis and reporting functions using publicly available information and data provided voluntarily by businesses in the interim.

European Commission issues first report evaluating the Unfair Trading Practices Directive

On 1 December 2025, the European Commission (the “Commission”) published its first report evaluating the Unfair Trading Practices Directive (Directive (EU) 2019/633) (the “UTP Directive”). The Commission’s report provides an early assessment of the effectiveness of the UTP Directive in achieving its goal of creating a fairer and more balanced agri-food supply chain and highlights areas for improvement. The Commission will consider the findings in this report in its review of the legislation in 2026.

Main findings

Although the UTP Directive has only been fully implemented for a short period, the report concluded there are encouraging signs it is having a positive impact on preventing and combating Unfair Trading Practices (“UTPs”) in the agricultural and food supply chain. While there were perceived improvements in the occurrence of UTPs, views on the effectiveness of the UTP Directive varied throughout the supply chain with farmers and suppliers in particular reporting positive trends. Notwithstanding an early positive experience, the report also highlighted persistent challenges that limit the UTP Directive’s effectiveness including low awareness among farmers, smaller suppliers and non-EU stakeholders, underreporting of complaints due to fear of retaliation and uneven enforcement approaches across Member States.

The Commission’s accompanying evaluation also highlighted significant differences in how Member States implemented the UTP Directive, with some Member States extending protections beyond the UTP Directive’s minimum requirements. As national approaches vary widely across the EU, the Commission found that enforcement remains fragmented. Moreover, proactive investigations are rare, with most enforcement relying on complaints rather than systematic monitoring. According to the report, only a limited number of complaints were received across all Member States, with a total of 4,610 investigations opened between 2021 – 2024. Of these, 4 Member States carried out 90% of investigations. While the overall number of investigations in the EU remains relatively low compared to the volume of sales transactions in the sector, the upward trend suggests growing engagement with UTPs.

Ultimately, the Commission concluded that while early results are positive, further efforts are needed to improve enforcement, raise awareness and ensure consistent application of the UTP Directive across all EU Member States.

Next steps

Following publishing of the report, the Commission commenced a consultation process aimed at gathering views on the challenges in the agri-food supply chain, possible policy options to address them, and their likely impacts. All evidence and feedback collected will inform the revision of the UTP Directive. Given the Commission’s intention to conduct a formal review of the UTP framework in 2026, companies operating in the agri-food supply chain should continue to monitor developments in this area to ensure readiness for any adjustments in enforcement standards or regulatory obligations.

Cross-border enforcement against unfair trading practices

In a related development, to complement the UTP Directive, the Commission had announced plans in late 2024 to introduce a new Regulation to address the cross-border element of UTPs and to further strengthen enforcement against UTPs prohibited under the UTP Directive. It is proposed that new Regulation would introduce a harmonised framework for cooperation between national enforcement authorities to address UTPs where suppliers and buyers are in different Member States or involve non-EU buyers. Overall, the new Regulation aims to close enforcement gaps under the UTP Directive and ensure consistent protection for suppliers across the EU.

If implemented, enforcement authorities will be able to request information from another Member State’s enforcement authority on whether an unfair trading practice has occurred and launch coordinated actions in cases of cross-border UTPs. The Council of the EU and the European Parliament reached a provisional agreement on this Regulation in November 2025.

Next steps

Companies should assess cross-border contracts for compliance with UTP rules, update internal procedures to reflect enhanced enforcement cooperation and prepare for information-sharing between EU authorities. The provisional agreement must now be endorsed by both the Council of the EU and the European Parliament before being formally adopted. Once adopted, the Regulation will enter into force on the twentieth day following its publication in the Official Journal of the European Union.

Food and Feed Safety Simplification Package – December 2025

Finally, in what was a key deliverable from the “Vision for Agriculture and Food” presented by the Commission earlier in 2025, December saw the announcement of a Food and Feed Safety Omnibus proposal, with a particular focus on biopesticides. The proposal for a Biotech Act, announced at the same time, also has relevance to the food sector in a number of ways and the draft legislation also seeks to amend the EU’s General Food Law.