The new CSRD Directive

The new CSRD Directive – Corporate Sustainability Reporting Directive – entails significantly higher requirements for companies’ sustainability reporting. The purpose is to ensure that the impacts of companies’ social and environmental activities are reported in a consistent manner, with increased comparability and improved quality of the information.
 

In February 2025, the EU adopted an omnibus package that adjusted certain timelines for the implementation of CSRD. Member States were given the option to introduce a temporary postponement – often referred to as “stop the clock” – to give companies more time to prepare. The Swedish government has therefore presented a legislative proposal that postpones the reporting obligation for certain companies by two years. The proposal is expected to enter into force on 31 December 2025.
 

Which companies are granted postponement – and from when?
 

Wave 1: Listed companies with more than 500 employees are not included in the postponement. They must continue to report under CSRD according to the original timeline – no changes here.
 

Wave 2: Large companies and parent companies of large groups* that either have fewer than 500 employees, or have more than 500 employees but are not listed, will be required to report under CSRD for the first time for financial years starting after 31 December 2026.
 

Wave 3: Small and medium-sized listed companies, as well as small and non-complex institutions and captive companies, will be required to report under CSRD for the first time for financial years starting after 31 December 2027.

*Companies are classified as large companies and parent companies of large groups if, for each of the two most recent financial years, they meet at least two of the following three criteria: more than 250 employees on average, total assets exceeding SEK 280 million, and net turnover above SEK 550 million.
 

The government does not propose any changes for the two-year postponement period. Instead, it refers to the previous provision stating that companies required to report under the earlier directive (NFRD) must continue to do so until CSRD applies.
 

📄 The Government’s legislative referral can be found here.