SwedenFAR
Wave 2 firms meeting new thresholds stay in CSRD scope
Wave 2 companies meeting the new 1,000-employee and turnover thresholds stay covered, while wave 1 companies below them would be exempt for years starting 1 January 2026 — but current rules apply until the law changes.
By Taxxa AI OyPublished 6 October 2026
Companies in wave 2 that meet the new thresholds remain covered by the sustainability reporting duty even after the new rules enter Swedish law.
FAR The reporting obligation applies to companies that in each of the last two financial years had an average of more than 1,000 employees and annual net turnover above 450 million euroFAR, stated as 4.9 billion kronor in the Swedish proposal. Both conditions must be metFAR, and the balance-sheet criterion is removed. Listed small and medium-sized enterprises are fully exempt from the reporting duty.
Wave 1 companies — large public-interest entities with more than 500 employeesFAR — are not covered by the postponement of the reporting date for waves 2 and 3, but they received extended phase-in relief through the "quick-fix" act. If the inquiry's proposal is enacted, wave 1 companies that do not meet the new thresholds are exempt from sustainability reporting for financial years beginning on 1 January 2026 or later.FAR Until the legislative amendments are decided, companies must comply with the rules currently in force.FAR
Suppliers in the value chain with an average of no more than 1,000 employees in the latest financial year become protected companies. A protected company may refuse to provide more information than the voluntary sustainability reporting standards require, and contractual terms demanding further information for the customer's statutory sustainability report are proposed to be void. A reporting company may rely on a written self-declaration from the supplier about its size unless it reasonably should know the declaration is wrong.
The proposal adds and extends several exemptions. Parent companies that are financial holding companies are exempt from group reporting where their subsidiaries have independent business models and operations. The subsidiary exemption is extended to large listed subsidiaries included in a group report. Companies may omit more sensitive information, covering trade secrets, security-classified data, personal privacy and national security, and a parent may omit information about subsidiaries acquired, merged or divested during the financial year. Sweden proposes not to use the directive's option to limit the board's collective responsibility for the digital tagging of the report.
Taxonomy reporting has already been simplified through delegated regulation (EU) 2026/73, which applies directly in Sweden without amendments to Swedish law. The revised ESRS are to apply to financial years beginning on 1 January 2027.FAR Companies outside CSRD may still need to provide sustainability information to stakeholders under the voluntary standard, which the Commission adopted on 3 July 2026.
Legal basis: the Omnibus directive as proposed for Swedish implementation in SOU 2026:27, delegated regulation (EU) 2026/73 on taxonomy reporting, and the revised ESRS and voluntary VSME-based standard adopted by the Commission.
Wave 1 companies with fewer than 1,000 employees and wave 2 companies should check both new thresholds against their last two financial years and follow the inquiry proposal before changing any reporting plans.