CSDDD: Corporate Sustainability Due Diligence Directive

In-scope EU and non-EU companies must identify, prevent, and address human rights and environmental impacts across their own operations and value chain, with documented due diligence and supervisory oversight in every Member State.

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Next deadline

26 July 2029: Application date for in-scope companies under the revised CSDDD

The data layer behind CSDDD compliance is built over multiple procurement cycles. Supplier engagement frameworks, contract clauses and risk methodologies signed today determine what is available when due diligence obligations begin to apply. Companies that already report under CSRD or run national supply chain regulations are using the transition period to consolidate one supplier-data foundation across all relevant regimes.

Regulation timeline

June 2024

Directive (EU) 2024/1760 enters into force after final adoption by the European Parliament and Council.

26. February 2026

Omnibus I Directive (EU) 2026/470 published in the Official Journal, narrowing CSDDD scope and amending due diligence obligations.

26. July 2028

Member States must transpose the revised CSDDD into national law.

1. January 2030

First financial year covered by the obligation to publish an annual statement on sustainability due diligence matters.

April 2024

Stop-the-Clock Directive (EU) 2025/794 postpones the first phase of application by one year.

18. March 2026

Omnibus I enters into force across the EU.

29. July 2029

Application date for in-scope companies. Risk-based due diligence obligations apply across own operations, subsidiaries and chain of activities.

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2024

June 2024
Directive (EU) 2024/1760 enters into force after final adoption by the European Parliament and Council.
2025

April 2024
Stop-the-Clock Directive (EU) 2025/794 postpones the first phase of application by one year.
2026

26. February 2026
Omnibus I Directive (EU) 2026/470 published in the Official Journal, narrowing CSDDD scope and amending due diligence obligations.
18. March 2026
Omnibus I enters into force across the EU.
2028

26. July 2028
Member States must transpose the revised CSDDD into national law.
2029

29. July 2029
Application date for in-scope companies. Risk-based due diligence obligations apply across own operations, subsidiaries and chain of activities.
2030

1. January 2030
First financial year covered by the obligation to publish an annual statement on sustainability due diligence matters.

osapiens Guide

CSDDD after Omnibus I: Build a Defensible Due Diligence Setup

The CSDDD has narrowed in scope, but the operational expectations for companies still affected remain demanding. Due diligence must be risk-based, traceable, and backed by reliable evidence.

This guide explains what changed under Omnibus I and shows how to build a continuous due diligence process connecting risk analysis, corrective measures, complaints, monitoring, and documentation.

What you will learn:

How the CSDDD scope, thresholds, and timelines have changed
What a defensible, risk-based due diligence process should include
How to connect risk signals with actions and evidence
Warning signs that may indicate gaps in your setup
How software can support supplier engagement and audit readiness

Download the guide to assess your due diligence setup and close the gaps.

What the regulation requires

In-scope companies must identify, assess, and address adverse impacts on human rights and the environment across their own operations, subsidiaries, and chain of activities.

The revised scope applies to EU companies with more than 5,000 employees and net worldwide turnover above €1.5 billion, and to non-EU companies generating more than €1.5 billion in EU turnover.

Direct (Tier 1) business partners are the primary focus for due diligence. Evidence of risk in deeper tiers triggers further investigation.

Due diligence obligations cover six areas:

Integrating due diligence into company policy and risk management
Identifying and prioritizing impacts
Preventing and mitigating potential harms
Remediating actual harms
Engaging stakeholders
Operating a grievance mechanism

Member States designate supervisory authorities and set penalties up to 3% of worldwide net turnover.

Operational challenges of CSDDD compliance

Scoping the chain of activities correctly

The revised CSDDD focuses in-depth assessment on direct business partners, with deeper investigation triggered only by plausible information of risk further upstream. Determining which partners are in scope, which trigger points warrant escalation, and how downstream relationships are treated requires a defined methodology applied consistently across the business.

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