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SwedenFAR

Outside CSRD, firms must choose how to report voluntarily

Most Swedish companies fall outside mandatory CSRD reporting under Omnibus; those reporting voluntarily must choose between the voluntary standard and simplified ESRS.

By Taxxa AI OyPublished 23 October 2026

Accounting & Reporting

Industry: Across industries

Most Swedish companies will fall outside mandatory sustainability reporting once the EU Omnibus package is implemented in Sweden.FAR The thresholds rise from 250 to 1,000 employeesFAR on average over the two most recent financial yearsFAR, combined with annual net turnover above EUR 450 millionFAR, with the balance-sheet threshold removedFAR. A Swedish inquiry (SOU 2026:27, delivered April 2026) proposes implementation at minimum levelFAR, with the new rules proposed to enter into force on 1 January 2027FAR. In practice, most companies no longer need to report under CSRD.FAR

The need for sustainability information has not disappeared. Investors, banks, customers and employees still request relevant and comparable information, and many companies find that reporting brings more structured analysis and helps focus sustainability work. There is therefore clear interest in continuing to report voluntarily.

The European Commission has adopted a voluntary standard based on the VSME recommendationFAR on 3 July 2026FAR for companies outside CSRDFAR, alongside a proposal for simplified ESRSFAR. The voluntary standard works as basic protection for companies outside CSRD. It gives structure and a common starting point, but offers more limited support for companies that want to use reporting as a strategic tool. For those companies it can be more relevant to consider reporting under simplified ESRS, which are proposed to contain fewer datapoints, a simpler structure and greater flexibility while preserving reporting qualityFAR. The revised ESRS are set to apply for financial years starting on or after 1 January 2027.FAR

In practice companies face a choice of ambition. The first path is to do enough: report what customers or banks ask for in dialogue, and use the voluntary standard as a checklist to show transparency and ability to cooperate. That can be right for smaller companies where demands come mainly from the value chain.

The second path is more demanding and more value-creating: use reporting as a tool for analysis, prioritisation and governance. Here the framework supports understanding of how sustainability issues affect the business model, the risk picture and strategy, not only structuring information.

Voluntary choice brings a comparability risk. When companies have greater freedom to choose what and how to report, users find the information harder to interpret. FAR has argued in consultation responses that simplifications must not come at the expense of clarity and comparability. Starting from common standards, even voluntarily, creates a common basis, reduces greenwashing risk and makes comparison and follow-up over time possible. That requires discipline: not selecting information only because it presents the business in a better light, and remaining consistent and clear.

Omnibus has brought uncertainty, with adjusted plans, paused projects and reconsidered investments. With less tightly regulated reporting there is room to reconsider purpose: from compliance to value. Voluntary reporting works best when it starts in the business, not in the rulebook — identifying the issues that truly affect the business, building a structure to follow them up, and communicating in a way that is relevant to stakeholders. The frameworks are there as support, but the company must set the direction.

Legal basis: CSRD as amended by the Omnibus 1 directive, the revised ESRS and the voluntary standard based on VSME, with Swedish implementation proposed in SOU 2026:27.

Review each client outside CSRD and agree whether voluntary reporting should follow the voluntary standard or simplified ESRS.

Sources