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2026.08.24
Response to consultation Relaxations in the requirements for sustainability reporting (SOU 2026:27)
SWETIC's response to the interim report on easing the requirements for sustainability reporting (SOU 2026:27)
Summary
SWETIC notes the proposals in the interim report regarding easing the requirements for sustainability reporting and the changes relating to the review of sustainability reports.
In light of the investigation's continued mission, SWETIC would like to particularly emphasize the importance of considering the possibility of allowing independent reviewers in the continued work. EU regulations give Member States the opportunity to allow so-called independent reviewers to review sustainability reports. SWETIC views this issue positively as part of the investigation's continued mission.
Views
The interim report addresses, among other things, issues relating to the review of sustainability reports and the competence requirements for those responsible for the review. In this context, SWETIC wants to highlight the competence and quality infrastructure that already exists within the TIC industry and that should be taken into account in the continued investigation into independent reviewers. The investigation assignment regarding independent reviewers points out, among other things, the need for requirements
and systems for:
- education and examination,
- accreditation,
- continuing education,
- quality control,
- supervision,
- sanctions and disciplinary measures.
SWETIC would like to emphasize that all of the above elements are already covered by established regulations that apply to accredited and independent auditors. The investigation assignment also highlights risks related to the sustainability audit being perceived
as less credible or of lower quality, that the connection between sustainability reporting and financial reporting can be weakened if different actors review them, and that a
change may require changes in accounting and corporate law legislation.
SWETIC believes that these risks are entirely preventable and would like to point out in particular the model that has been introduced in Denmark. There is legislation on independent auditors of sustainability reporting (LOV no. 52 of 28/01/2025 (Gældende) – Lov om ufhængige afklæringsudbydere vedendret Bæredygtighedsrapportering). SWETIC believes that a similar model could strengthen the market for auditing sustainability reporting.
The TIC industry has already begun work in this area, as well as in other relevant and planned regulations linked to the green transition, such as ECGT, Green Claims and
ESPR/Ecodesign. Together, these regulatory frameworks can be seen as different layers in the same European system to make sustainability information measurable, traceable, verifiable and credible. Independent reviewers can contribute to this through the already established quality infrastructure
which are found in the TIC industry.
Conclusion
SWETIC would like to emphasize the importance of taking into account the existing expertise and quality infrastructure within the TIC industry in the investigation's continued work on the issue of independent review of sustainability reports.