European Union Under review
Corporate Sustainability Reporting Directive
Omnibus lifted employee thresholds and delayed later reporting waves by two years.
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The EU flagship due diligence law obliging large companies to identify, prevent and remedy human rights and environmental harms across their chains of activities.
Omnibus negotiations settled a narrowed scope; member state transposition now runs to July 2027.
In plain language
The CSDDD entered into force in July 2024 as the most consequential due diligence law yet adopted, then spent the following two years being reshaped by the Commission's simplification omnibus. The stop-the-clock directive of 2025 pushed transposition deadlines back, and the substantive omnibus negotiations narrowed the scope to only the very largest companies while removing the harmonised civil liability regime.
For suppliers in the Global South the practical effect is a longer runway but a more concentrated compliance demand. Fewer buyers are directly in scope, yet those buyers are the largest purchasers in most agricultural and garment supply chains, and their contractual cascading of obligations has already begun well ahead of the formal deadlines.
The directive still requires in-scope companies to embed due diligence into policies, identify actual and potential adverse impacts, prevent and mitigate them, establish complaints procedures, monitor effectiveness, and communicate publicly. Climate transition plan obligations survived the omnibus in modified form.
Obligations
Companies must identify and assess actual and potential adverse impacts, prioritising by severity and likelihood rather than auditing everything at once.
Where impacts are identified, companies must take appropriate measures, use leverage with business partners, and provide or enable remediation for harms they caused or contributed to.
Consultation with affected workers, communities and their representatives is required at several stages of the due diligence cycle.
In-scope companies must adopt and put into effect a transition plan for climate change mitigation aligned with the Paris Agreement.
Timeline
Directive entered into force following publication in the Official Journal.
Commission published the first simplification omnibus proposing significant amendments.
Stop-the-clock directive adopted, delaying transposition and first application dates.
Political agreement reached on the substantive omnibus package, narrowing scope and removing the EU-wide civil liability regime.
Revised member state transposition deadline.
Expected first application date for the largest companies.
Changelog
Tracker entry revised to reflect the consolidated omnibus text and updated transposition calendar.
Scope thresholds and civil liability treatment updated following the trilogue outcome.
Sources
Same jurisdiction
Omnibus lifted employee thresholds and delayed later reporting waves by two years.
Read →Application began for large operators on 30 December 2025; SME obligations follow on 30 June 2026.
Read →Commission building the forced labour risk database ahead of application in December 2027.
Read →