Who should report under the CSRD?
The CSRD entered into force on 1 July 2024 and will apply to different categories of companies at different times. Right now, there is a proposal from the European Commission to simplify certain parts of the CSRD and to postpone reporting for certain groups of companies. The proposal is called Omnibus I.
Omnibus I proposes that initially, only large companies with more than 1000 employees and with a balance sheet total of more than EUR 25 million or more than EUR 50 million in net sales should be covered by the CSRD. In addition, it is proposed to postpone the application of all reporting requirements of the CSRD for certain companies that are required to report for the financial years 2025 and 2026 and to postpone the deadline for the application of the first wave of the CSRD to 26 July 2028. But this is only a proposal and until a decision is made, the first implementation of the CSRD in Swedish law still applies, which states that:
Reporting for the financial year 2024/25
Applies to large Swedish companies and groups of public interest (banks, insurance companies and listed companies) with more than 500 employees and that either have more than SEK 280 million in total assets or SEK 550 million in net sales.
Reporting for the financial year 2025
Other large companies and groups that meet at least two of the following conditions in each of the last two financial years;- the average number of employees has amounted to more than 250- the balance sheet total has amounted to more than SEK 280 million- net sales have amounted to more than SEK 550 million
Reporting for the financial year 2026
Regulated market SMEs. For these companies, there is an option to postpone the introduction by two years until 2028.
Reporting for the financial year 2028
Non-EU companies with branches/subsidiaries of a certain size.
In the EU, the CSRD initially applies to 50,000 companies. However, the requirements will affect smaller companies in the supply chain, as the large companies need sustainability data from their subcontractors.