CSRD Reporting Sweden: Guide for Swedish SMEs

Introduction

Swedish businesses are known for their strong sustainability culture — and the Corporate Sustainability Reporting Directive (CSRD) builds directly on that tradition. Since the EU’s Omnibus I simplification (in force 18 March 2026), only the largest Swedish companies report under CSRD, while many more provide sustainability data to clients and banks that do.

Even if your SME isn’t directly covered, you’ll soon encounter data requests as part of larger companies’ supply chain obligations. The EU’s Voluntary SME Standard (VSME) gives Swedish small and medium-sized enterprises a practical, simplified way to disclose sustainability information proportionately.

This guide explains how CSRD applies in Sweden, which companies are in scope, and how Swedish SMEs can start reporting effectively.

For background on size requirements, see Is My Company Too Small for CSRD? Size Questions Answered.

1. How CSRD Applies in Sweden

Sweden transposed the CSRD into national law in 2024 through amendments to the Årsredovisningslagen (Annual Accounts Act) and related auditing regulations. The Swedish Finansinspektionen (FI) and the Swedish Companies Registration Office (Bolagsverket) oversee compliance and report filing.

Timeline for Swedish Companies

2. Swedish Size Thresholds for CSRD Applicability

Since Omnibus I (in force 18 March 2026), CSRD applies only to companies meeting both of the following criteria:

The earlier “two of three” test based on 250 employees, SEK 550 million turnover, or SEK 275 million balance sheet no longer applies, and the listed-SME track has been removed. If your company doesn’t meet both thresholds, you’re not required to report under CSRD — but you may still need to provide data for business partners that do.

Only a small number of Sweden’s largest companies report directly under CSRD, while tens of thousands of Swedish SMEs are affected indirectly through value-chain data requests.

3. The Voluntary SME (VSME) Standard in Sweden

The VSME Standard, developed by EFRAG, allows small and medium-sized companies to report sustainability data voluntarily and in a simplified format.

It’s fully compatible with Swedish reporting culture, aligning with the Annual Accounts Act and sustainability practices encouraged by Tillväxtverket and Almi.

VSME Reporting Modules

Reports can be published in Swedish or English, depending on audience and investor preferences.

4. Where and How to File CSRD Reports in Sweden

For companies under mandatory CSRD:

• Reports must be submitted to Bolagsverket together with annual financial statements.
• They must be prepared in digital XHTML format and follow the European Sustainability Reporting Standards (ESRS).
• Assurance must be carried out by authorised revisorer (auditors) under limited assurance standards.

For voluntary VSME reporters:

• Reports do not need to be filed with authorities.
• SMEs can share them directly with banks, clients, or investors.
• It’s recommended to retain data and documentation for at least seven years, in line with Swedish accounting rules.

5. How Swedish SMEs Can Get Started

Step 1: Determine your status

Confirm whether your company is “large” under the Swedish thresholds. If not, adopt the VSME Standard voluntarily.

Step 2: Identify key sustainability topics

Start with material topics that match your business activity — usually energy, workforce, and waste for most SMEs.

Step 3: Set up data collection

Use existing records such as invoices, HR data, and supplier information. For a practical setup, see How to Integrate CSRD Data Collection into Existing Workflows.

Step 4: Prepare a short narrative report

Explain your company’s main impacts, policies, and improvement goals in simple terms. Example:

“We aim to reduce energy consumption by 10% by 2026 through equipment upgrades and employee training.”

Step 5: Consider optional assurance

Although not mandatory, limited assurance by your financial auditor increases trust and readiness for future requirements.

For audit preparation, read CSRD Audit Requirements for SMEs.

6. Local Support and Guidance in Sweden

Swedish SMEs can access national support from:

• Tillväxtverket (Swedish Agency for Economic and Regional Growth) – Guidance for SME sustainability reporting.
• Bolagsverket – Official filing portal for CSRD and financial reports.
• FAR (Institute for the Accounting Profession) – Professional guidance on sustainability assurance.
• Almi Företagspartner – Advisory and funding for sustainability-driven SMEs.
• Svenskt Näringsliv (Confederation of Swedish Enterprise) – Business network offering ESG and CSRD resources.

7. Example: Simplified SME Disclosure (in Swedish/English)

Företag: NordTek AB Verksamhetsår: 2025 Antal anställda: 42 Energiförbrukning: 85 000 kWh (100 % förnybar el) Avfall: 3,2 ton (70 % återvunnet) Utbildning: 8 timmar per anställd Jämställdhet: 40 % kvinnor i ledningsgruppen Policy: Etikkod och klimatstrategi antagna 2025

This example meets the VSME framework and demonstrates transparency without requiring full ESRS disclosure.

Frequently Asked Questions

Is CSRD mandatory for all Swedish SMEs?

No. Since Omnibus I, no SME reports under CSRD — only companies with more than 1,000 employees and net turnover above €450 million must report. SMEs can respond to data requests voluntarily using the VSME Standard.

Can we submit reports in English?

Yes, English reports are acceptable, though many SMEs also publish a Swedish summary for local audiences.

Do SMEs need external assurance?

Not for voluntary reports, but limited assurance by your auditor is recommended for credibility.

How long should data be stored?

At least seven years, consistent with Swedish bookkeeping and audit requirements.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464).
• VSME – Voluntary sustainability reporting standard for SMEs.
• ESRS – European Sustainability Reporting Standards.
• Limited assurance – Moderate external verification of sustainability data.
• Revisor – Certified auditor authorised to conduct assurance in Sweden.

Conclusion

Swedish SMEs are not required to report under CSRD, but responding well to sustainability data requests is a strategic opportunity to strengthen transparency, efficiency, and reputation.

Start small using the VSME Standard, focus on material topics, and integrate sustainability data into everyday management. With Sweden’s strong tradition of environmental and social responsibility, most SMEs are already well positioned to succeed.

To plan your reporting schedule and milestones, check the Annual CSRD Reporting Calendar.