Omnibus Sweden: 5 billion threshold, March 2027 start

SOU 2026:27 submitted inquiry proposals in April 2026 for minimum-level implementation. The government submitted its referral on 22 October. Three operative changes follow in the new referral text: the referral as the vehicle, a higher Swedish turnover figure, and a later entry date.

Reporting is required only where a company in each of the two latest financial years averaged more than 1,000 employees and had annual net turnover above 450 million euro.FAR The Swedish proposal states the turnover test as 5 billion kronorFAR, up from 4.9 billion in the inquiry. Both conditions must be met. The balance-sheet link as a threshold is removed in line with the directive. As a result of the higher thresholds, small and medium-sized listed companies are fully exempted from sustainability reportingFAR. The higher thresholds cut the number of companies in scope by about 90 percent.

To shield smaller actors the referral introduces protected companies. A protected company is an undertaking in the value chain that averaged at most 1,000 employees in the latest financial year. Such companies may refuse information beyond the voluntary sustainability-reporting standards. Contract terms requiring more information than the voluntary standards for the purpose of meeting the customer statutory report are proposed to be void. A reporter may rely on a written supplier self-declaration on size unless it reasonably should know it is wrong.

New and extended exemptions apply. A parent that is a financial holding company is exempted from group reporting where subsidiaries have independent business models and operations. The subsidiary exemption is extended to large listed subsidiaries included in a group report. The right to omit information is extended to trade secrets, security-classified data and data concerning personal privacy or national security. A parent may omit information on subsidiaries acquired, merged or leaving the group during the year.

On the directive options the referral does not use the possibility to limit the board collective responsibility for digital tagging. Companies are not required to tag reports digitally until the Commission adopts the specific tagging rules and taxonomy.

The new rules are proposed to enter into force on 19 March 2027, with early application for some. Wave-1 companies that fail the new thresholds are exempted from sustainability reporting for financial years starting 1 January 2026 or later.FAR A three-year exemption applies for value-chain information that is unavailable, counted from the first year the company becomes reportable under the new rules. Until amendments are decided companies must follow current rules.FAR Wave 2 and 3 start-date postponement is already in Swedish law; wave 1 large public-interest companies with more than 500 employees are not covered by that postponement but received extended phase-in relief through the quick-fix act.

The background is the Commission 26 February 2025 Omnibus package to simplify sustainability reporting, in force since 18 March 2026 with national transposition by 19 March 2027 except CSDDD parts due 26 July 2028FAR. It raises thresholds from 250 to 1,000 employeesFAR with the 450 million euro turnover testFAR, simplifies ESRS and limits CSDDD. Revised ESRS apply for years starting 1 January 2027; the voluntary VSME standard was adopted 3 July 2026; taxonomy reporting was simplified by directly applicable Delegated Regulation (EU) 2026/73.

Advisers should re-test each client against both thresholds for the two latest years, identify wave-1 clients falling out for 2026FAR, and freeze value-chain requests to protected-company scope with self-declarations.

Legal basis: Europaparlamentets och rådets Omnibus-direktiv on sustainability-reporting relief with transposition 19 March 2027, SOU 2026:27 as the superseded April inquiry vehicle, and regeringens lagrådsremiss Lättnader i kraven på hållbarhetsrapportering of 22 October with 5 billion kronor and 19 March 2027.