How Sweden plans to implement the EU's due diligence directive
A Swedish government inquiry has presented its proposal for how the EU's Corporate Sustainability Due Diligence Directive, CSDDD, should be implemented in Swedish law. Here is what is new, and how Ethos can help you start preparing now.
What is new in the proposal?
Supervisory authority. The National Board of Trade Sweden, Kommerskollegium, is proposed as the authority responsible for supervising the law. The mandate brings increased costs for Kommerskollegium. Ongoing supervision is proposed to be financed through fees paid by the companies covered by the law, while the initial setup is financed through the state budget.
Damages and injunctions. The inquiry assesses that Swedish tort law already meets the EU directive's requirements on compensation for damage caused by a company's failure to meet its obligations. No special Swedish liability rules are therefore proposed.
Entry into force. The law is proposed to take effect on 26 July 2029, the same date that applies across the EU. On this point the inquiry proposes no Swedish deviation.
Thresholds. The same thresholds as in the EU directive are proposed for Sweden: more than 5,000 employees and net turnover of more than EUR 1.5 billion. The employee count is calculated as an average expressed in full-time equivalents (FTE). The amount is stated in euro, with the addition that amounts in another currency are to be converted using the average exchange rate for December of the year before the relevant financial year.
Number of companies in scope. The inquiry estimates that 70 to 90 Swedish companies will be directly covered by the law. Beyond that, the requirements will have indirect consequences for subsidiaries and for companies within the covered companies' chains of activities.
A related reform on batteries. In the same report, the inquiry also proposes that the Swedish Energy Agency, Energimyndigheten, be given the task of market surveillance of compliance with the EU Battery Regulation.
In addition, the proposal covers definitions and clarifications, the requirements to be placed on companies and how companies are to be supervised, among other things.
How Ethos can help you prepare
Even though the law has not yet been adopted, the direction is clear, and companies already close to the thresholds would be wise to start preparing. A few examples of how Ethos can support you:
A gap analysis of your current procedures, policies and processes against the requirements the proposal would introduce.
Setting up and further developing your human rights due diligence process, HRDD in compliance with the requirements.
Building on the work you already do under CSRD, EUDR, EUBR, EU FLR or conflict minerals, so it becomes one shared foundation rather than parallel processes.
For more detailed information, read the full proposal here: https://regeringen.se/contentassets/190828bcbcfb4b48b5ecef119c70545c/en-lag-om-foretagsansvar--genomforande-av-eu-direktivet-om-tillborlig-aktsamhet-for-foretag-i-fraga-om-hallbarhet-sou-202656.pdf
Contact Melina Hägerö to know more!
Melina Hägerö
melina.hagero@ethos.se
About Ethos
Ethos is one of the Nordic region’s oldest and leading sustainability-focused consultancies, with over 20 experts covering environmental issues, human rights, and anti-corruption. We help medium to large companies and financial market actors address sustainability challenges—from strategic boardroom decisions to operational policy compliance on the factory floor. Ethos tailors each project to clients' needs, supporting compliance with CSRD, SFDR, EU Taxonomy, and CSDDD regulations while guiding their strategic sustainability journeys.