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Glossary termPublished inCSDDD

Appropriate measures

What does "Appropriate measures" mean under the CSDDD?

Measures that are capable of achieving the objectives of due diligence by effectively addressing adverse impacts in a manner commensurate to the degree of severity and the likelihood of the adverse impact, and reasonably available to the company, taking into account the circumstances of the specific case, including the nature and extent of the adverse impact and relevant risk factors

Defined in / by

Last updated: 13 October 2026.

A standard of conduct

The definition sets three tests in one sentence. The measures must be capable of achieving the objectives of due diligence by effectively addressing adverse impacts. They must be commensurate to the degree of severity and the likelihood of the impact. And they must be reasonably available to the company, taking into account the circumstances of the specific case, including the nature and extent of the adverse impact and relevant risk factors.

The wording asks what is capable, commensurate and reasonably available. It does not promise that an impact will not occur, and it ties the duty to what the company can reasonably do in its circumstances. The term appears in Articles 6, 7, 8, 10, 11, 13, 14, 15, 16, 19 and 20 of the 2024 text, and Directive (EU) 2026/470 replaced parts of several of those articles. Article 8(2), as replaced, turns the identification of adverse impacts itself into a duty to take appropriate measures.

Because the standard is set in each article rather than once, a company reading Article 10 on prevention reads the same three tests as one reading Article 13 on engagement, and each applies them to a different object.

Questions and answers

Does appropriate measures mean a company must prevent every adverse impact?

The definition ties the standard to what is reasonably available to the company and commensurate to severity and likelihood. Whether a particular outcome is required in a case is a question for counsel.

Who decides what is reasonably available?

The definition does not name a decider. Supervisory authorities designated under Article 24 can require information and investigate compliance (Article 25(1)).

Glossary

  • Risk factors

    Facts, situations or circumstances that relate to the severity and likelihood of an adverse impact, including facts, situations or circumstances at the level of the business partner, such as whether the business partner is not a company covered by this Directive or other comparable mandatory sustainability due diligence legal acts; at the level of geography and context, such as the level of law enforcement with respect to the type of adverse impact; and at the level of sectors, of business operations, and of products and services.

  • Severity of an adverse impact

    The scale, scope or irremediable character of the adverse impact, taking into account the gravity of an adverse impact, including the number of individuals that are or may be affected, the extent to which the environment is or may be damaged or otherwise affected, its irreversibility and the limits on the ability to restore affected individuals or the environment to a situation equivalent to their situation prior to the impact within a reasonable period of time.

Regulations

  • Corporate Sustainability Due Diligence Directive (CSDDD)

    The Corporate Sustainability Due Diligence Directive is Directive (EU) 2024/1760. After Omnibus I, Member States must transpose it by 26 July 2028 and apply it from 26 July 2029, to companies with more than 5,000 employees and EUR 1.5 billion in net worldwide turnover. The Netherlands has a draft bill, the Wivo, which names the ACM as supervisor.

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