On 24 February 2026, the EU formally adopted the Omnibus 1 package, which significantly simplifies and reduces the administrative burden related to sustainability reporting (CSRD) and due diligence (CSDDD).
In connection with this, Denmark’s Minister for Industry, Business and Financial Affairs, Morten Bødskov, has issued Executive Order No. 328, postponing the CSRD obligation for some of the largest Danish companies. Below, we outline what this means for SMEs.
The executive order applies to large companies in accounting class D, that:
- have more than 500 employees
- would otherwise have been subject to the new rules in sections 99(2) and 99a of the Danish Financial Statements Act
- and in two consecutive financial years do not exceed at least one of the following thresholds:
- DKK 3.53 billion in net turnover
- 1,000 full-time employees.
For these companies, this means that they:
- do not have to report under CSRD/ESRS for the financial years 2025 and 2026
- must instead apply the previous statement on corporate social responsibility under section 99a
- may voluntarily choose to report under the new rules if they wish to prepare in advance.
The rules also apply to parent companies preparing consolidated financial statements, where the thresholds are assessed at group level.
If a company has already appointed a sustainability auditor, it may deregister the auditor without a separate general meeting resolution – however, only until the next ordinary general meeting after the rules enter into force.
What does this mean for accounting class C (large) companies and SMEs?
Executive Order No. 328 applies only to accounting class D companies. Class C (large) companies are not included in the temporary postponement.
A qualified expectation is that Omnibus 1 I will raise the reporting thresholds, meaning that only companies with both very high turnover (around DKK 3.53 billion) and more than 1,000 employees will remain subject to CSRD from 2027.
This would mean that many Danish class C (large) companies – and all SMEs – would no longer be directly subject to CSRD under the new EU thresholds.
However, this does not mean that sustainability requirements for SMEs have “disappeared”.
What will happen from 2027 – and what should SMEs do now?
The EU intends to narrow the group of companies directly subject to CSRD from 2027. The largest companies in class D will receive a temporary postponement and will revert to the previous corporate social responsibility statement for the financial years 2025 and 2026.
For class C (large) companies and SMEs, we are currently awaiting the upcoming amendment to the Danish Financial Statements Act, which will implement the new EU thresholds in Danish legislation.
However, fewer direct legal requirements do not mean fewer expectations:
Large customers, banks and investors already have ESG on their agenda, and banks increasingly expect reliable and well-documented ESG data as part of their credit assessments.
For this reason, it still makes sense for SMEs to work systematically with sustainability data, processes and governance.
Not only to comply with future regulation, but also to strengthen market position, gain better oversight and deliver reliable data when customers and banks request it.
Do you have questions about CSRD?
Are you unsure how the new CSRD rules affect your business? We can help you clarify the implications and prioritise your next steps.
