Net Zero Compare
Denmark Sustainability Reporting under the Financial Statements Act

Denmark Sustainability Reporting under the Financial Statements Act: Denmark Sustainability Reporting Law: Financial Statements Act and CSRD

Maílis Carrilho
Written by Maílis Carrilho
Updated on May 28th, 2026

Summary

Denmark requires sustainability reporting under the Financial Statements Act, historically via Section 99a and now expanded through CSRD implementation. In-scope companies must disclose policies, due diligence, risks, impacts, and outcomes related to sustainability, with increasing alignment to ESRS standards. Group-level reporting can exempt subsidiaries under strict conditions. Enforcement includes fines, corrective orders, and potential management liability. A Danish postponement approach may delay CSRD reporting for some companies, but legacy sustainability reporting remains mandatory during the transition.

Details

Jurisdictions
  • Denmark
Mandatory for

Legally binding for:

Large Danish companies and listed entities falling within the non-financial reporting and CSRD scope.

Parent companies are responsible for consolidated sustainability reporting.

Exemptions

Subsidiaries may be exempt where a parent company provides compliant group-level reporting.

Small and micro-entities outside statutory thresholds are generally excluded.

Deep dive

2 min read
Updated May 28, 2026

📩 Stay ahead of climate regulation and reporting shifts

Regulatory updates, reporting standards, and new climate software — distilled into one concise weekly brief for decision-makers.

Thanks for signing up. Please check your inbox to confirm your subscription.

Practical updates. Once per week.


What’s Required

Denmark requires in-scope companies to disclose sustainability information as part of their statutory annual reporting under the Danish Financial Statements Act.

Key requirements include:

  • Disclosure of policies, due diligence processes, principal sustainability risks and impacts, and outcomes.

  • Description of the business model and how sustainability risks and opportunities affect strategy and performance.

  • Alignment with the EU Corporate Sustainability Reporting Directive (CSRD) architecture and the European Sustainability Reporting Standards (ESRS), once applicable.

  • Sustainability statements may be included directly in the annual report or published separately with a clear cross-reference.

  • Group reporting may satisfy subsidiary obligations where legal conditions are met.

Important Deadlines

  • FY 2024 reporting (published in 2025): first CSRD reporting cycle for companies in the initial wave.

  • Subsequent waves follow EU phasing rules.

  • A Danish “stop-the-clock” approach discussed in late 2025 may postpone CSRD reporting by two years for certain companies not yet in scope, while maintaining legacy-style reporting in the interim.

Current Status

CSRD has been transposed into Danish law through amendments adopted in 2024. Section 99a-style sustainability reporting remains operational and is expected to apply until postponed CSRD obligations enter into force for affected companies.

Penalties for Non-Compliance

  • Administrative fines for missing or deficient sustainability disclosures.

  • Corrective orders issued by the Danish Business Authority.

  • Periodic penalty payments until compliance is achieved.

  • Potential liability for management members responsible for reporting.

Examples of Known Violations

  • Failure to publish mandatory sustainability statements.

  • Incomplete or purely descriptive disclosures lacking required risk, policy or outcome information.

  • Failure to correctly rely on group reporting exemptions.

Resources


Maílis Carrilho
Added by:
Maílis Carrilho
Sustainability Research Analyst
Maílis Carrilho is a Sustainability Research Analyst (Intern) at Net Zero Compare, contributing research and analysis on climate tech, carbon policies, and sustainable solutions. She supports the team in developing fact-based content and insights to help companies and readers navigate the evolving sustainability landscape.
Our principle

Cut through the green tape

We don't push agendas. At Net Zero Compare, we cut through the hype and fear to deliver the straightforward facts you need for making informed decisions on green products and services. Whether motivated by compliance, customer demands, or a real passion for the environment, you’re welcome here. We provide reliable information. Why you seek it is not our concern.

Added on May 27, 2026 by Maílis Carrilho · Updated on May 28, 2026