European UnionAmended
Corporate Sustainability Reporting Directive
Omnibus narrowed scope to 1,000 employees from FY2027; first wave reporting continues with opt-outs.
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Directive requiring large companies to identify and mitigate human rights and environmental risks across their operations and supply chains.
Omnibus I in force since March 2026; transposition due July 2028 and application from July 2029.
In plain language
The Corporate Sustainability Due Diligence Directive requires large European companies and certain non-EU companies selling into Europe to carry out due diligence on human rights and environmental risks throughout their operations and supply chains. After a political compromise in December 2025, the scope was narrowed to companies with more than 5,000 employees (down from 1,000), though the definition of a "large" company will also include those with over 250 million euros in annual turnover. The directive applies to companies in higher-risk sectors including textiles, agriculture, mining and chemicals, as well as certain financial services.
The due diligence process requires companies to identify actual and potential adverse impacts on human rights and the environment, take measures to prevent or mitigate them, and establish a grievance mechanism. Companies must also conduct scenario analysis to assess financial risks from climate change and other environmental factors. Smaller suppliers are protected under an exception: companies may not require suppliers with fewer than 500 employees to disclose information beyond what EU sustainability reporting standards (ESRS) already require, and even then only when it is necessary and proportionate.
A significant change from the original proposal: the EU-wide civil liability regime was removed in the omnibus compromise, meaning companies face enforcement through member state authorities rather than a single European private right of action. Member states must transpose the directive by 26 July 2028, with obligations applying from 26 July 2029. The directive applies to large EU companies and non-EU companies with significant turnover in European markets regardless of where they are registered.
Obligations
Identify, prevent and mitigate adverse impacts on human rights and environment across operations and supply chains.
Establish a transparent channel for workers, communities and stakeholders to raise concerns about impacts.
Assess financial risks from climate change and environmental factors on the company's business.
Maintain documented knowledge of supply chain structure, including Tier 1 and critical Tier 2 suppliers.
Do not require information from suppliers under 500 employees beyond ESRS standards, only when necessary and proportionate.
Take corrective action to cease, mitigate or remedy identified adverse impacts.
Disclose due diligence processes and outcomes in sustainability reports under ESRS; public access required.
Ensure contractual clauses require business partners to comply with due diligence expectations.
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, moving transposition to July 2027 at that stage.
Political agreement narrowed scope to companies above 5,000 employees and removed the EU-wide civil liability regime.
Omnibus I, Directive (EU) 2026/470, published in the Official Journal.
Amending directive entered into force with the revised calendar
Commission guidelines and model contractual clauses due.
Member state transposition deadline.
Obligations apply to in-scope 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.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Sources
Same jurisdiction
Omnibus narrowed scope to 1,000 employees from FY2027; first wave reporting continues with opt-outs.
Read →Second postponement published one week before application; large operators now start on 30 December 2026.
Read →Commission published its enforcement guidelines on 30 June 2026, alongside a provisional list of national competent authorities.
Read →