CSDDD 2026 after Omnibus I – which companies are covered and what needs to be done?
Share
Short answer: The CSDDD has been simplified by Directive (EU) 2026/470. The mandatory scope has been focused on very large companies. For EU companies, the main threshold is now more than 5,000 employees and more than 1.5 billion euros in global net turnover. Member states must implement the rules by July 26, 2028, and they are generally to start applying from July 26, 2029.
What is the CSDDD?
The Corporate Sustainability Due Diligence Directive regulates companies' obligations to work in a structured manner with negative impacts on human rights and the environment within their own operations, subsidiaries, and relevant parts of the chain of activities.
What does Omnibus I entail?
| Question | Current 2026 |
|---|---|
| Size threshold | More than 5,000 employees and more than 1.5 billion euros in global net turnover for EU companies according to the amended main scope following Directive (EU) 2026/470. |
| National implementation | By July 26, 2028. |
| Application | Generally from July 26, 2029. |
| SME impact | Smaller companies may still face contractual and information requirements as suppliers, but are not automatically covered by the CSDDD as directly liable parties. |
What does a practical due diligence process look like?
- Map operations and supply chain.
- Identify and prioritize actual and potential negative impacts.
- Integrate requirements into policy, purchasing, and agreements.
- Use supplier code, DDQ, and documented risk classification.
- Create corrective action plans where deficiencies are discovered.
- Implement a complaints/grievance process and follow-up.
- Document decisions, evidence, and follow-up so that the work can be audited.
Supplier agreements are not enough on their own
A Supplier Code of Conduct can be an important control instrument but should be linked to actual risk assessment, follow-up, escalation, and corrective measures. Merely obtaining a signature from a supplier is not the same thing as a functioning due diligence process.
Frequently asked questions
Are small and medium-sized enterprises (SMEs) directly covered?
As a general rule, no, not by the new direct scope thresholds. However, they may be affected as business partners to companies that are covered.
Is the CSDDD the same thing as the CSRD?
No. The CSRD is about sustainability reporting. The CSDDD is about due diligence and the management of negative impacts.
Should one start preparing before 2029?
Yes, for companies that are likely to be covered, supplier mapping, risk data, agreements, and processes are multi-year tasks.
See Supplier Code & ESG Due Diligence 2026/2027.
Related guides
More working materials: See more templates for EU compliance and product regulations.
Sources
This guide provides general information and does not replace legal advice or scope assessment for a specific corporate group.
