Sweden proposes CSRD reporting only above 1,000 staff plus SEK 5bn turnover

Companies and groups stay inside mandatory sustainability reporting only when they average more than 1,000 employees in each of the last two financial years and report annual net turnover above EUR 450 million.FAR Both conditions must be met.FAR The Swedish draft states the turnover limit as SEK 5 billion.FAR The balance-sheet threshold as a reporting trigger goes away. The change cuts roughly 90% of companies out of the duty when compared with the current 250-employee starting point.

Small and medium-sized listed companies leave the duty entirely. That exemption matters for listed SMEs that have been preparing data collection and assurance processes: under the proposal they do not report at all, while larger listed subsidiaries can use the extended subsidiary exemption when they are covered by a group report.

Suppliers and other value-chain companies with on average no more than 1,000 employees in the last financial year count as protected companies. A protected company may refuse information requests that go beyond the EU voluntary sustainability-reporting standards. Contract terms that demand more information for the customer's statutory sustainability report become invalid. A reporting company may rely on a written self-declaration from the supplier about its size unless it reasonably should know the statement is wrong. A three-year exemption applies to value-chain information that is not available, counted from the year the company first becomes reporting-obliged under the new rules.

Financial holding companies whose subsidiaries run independent business models and operations are exempt from group-level reporting. The existing subsidiary exemption is extended to large listed subsidiaries included in a group report. Companies may also omit information acquired or lost through acquisitions, mergers or disposals during the year, information covered by trade secrets, security-classified data, personal privacy or national security, and must still describe material events affecting companies that entered or left the group during the year.

The higher thresholds also govern the duty to disclose intangible key resources. The government takes the view that the reference to Chapter 6, Section 10 of the Årsredovisningslagen already limits that disclosure duty to companies inside the new reporting scope, so no separate legislative amendment is needed. FAR has asked for clearer guidance on which companies that covers, how the disclosure links to sustainability reporting, what to add beyond ESRS, and how to assess whether a financial holding company takes part in managing a subsidiary. The government proposes to apply the directive definition of financial holding companies directly, without a separate Swedish definition.

The proposal implements the EU Omnibus changes of spring 2026 at minimum level. The Omnibus directive entered into force on 18 March 2026 and must be transposed by 19 March 2027, except for the due-diligence parts due by 26 July 2028. The Swedish rules are proposed to enter into force on 19 March 2027. Companies in the first reporting wave that already apply the post-30 June 2024 wording apply the new scope to financial years beginning on or after 1 January 2026. Transitional provisions that kept some companies reporting under older provisions are proposed for repeal. Until parliament decides, companies remain under the rules in force.

Legal basis: the government lagrådsremiss implementing Omnibusdirektiv (EU) 2026/470 on sustainability reporting, with Årsredovisningslagen (1995:1554) 6 kap. 10 §.