---
title: "Corporate Sustainability Due Diligence Directive (CSDDD)"
description: "The CSDDD applies from 26 July 2029 after Omnibus I, to companies with over 5,000 employees and EUR 1.5 billion turnover. See the Dutch bill and dates."
canonical: "https://gencompl.ai/regulations/csddd"
language: "en-US"
type: "Regulation"
published: "2026-10-13T17:43:04.582Z"
modified: "2026-10-13T20:53:30.542Z"
---

# 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.

Also known as: CS3D, Directive (EU) 2024/1760, ketenzorgplicht

**When does the CSDDD apply, and which companies does it cover?**

[Home](https://gencompl.ai/) › [Regulations](https://gencompl.ai/regulations) › Corporate Sustainability Due Diligence Directive (CSDDD)

## When does the CSDDD start to apply?

**Member States must transpose the CSDDD by 26 July 2028 and apply their national measures from 26 July 2029.** [Directive (EU) 2026/470](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202600470), the first Omnibus package, moved both dates back by two years and narrowed the Directive to companies with more than 5,000 employees and more than EUR 1.5 billion in net worldwide turnover. Reporting under Article 16 follows for financial years starting on or after **1 January 2030**.

No Dutch statute exists yet. As at 13 October 2026 the *Wet internationaal verantwoord ondernemen* is a draft bill: its [second consultation](https://www.internetconsultatie.nl/wivo2/b1) closed on 3 August 2026, and it names the ACM as supervisor. Smaller companies are not in scope themselves. They meet the Directive only as business partners in the chain of activities of a company that is.

Last updated: 13 October 2026. Checked against the Official Journal texts of Directives (EU) 2024/1760, 2025/794 and 2026/470, the Commission's CSDDD page, the Dutch consultation page and the ACM's feasibility and enforceability test.

## At a glance

- **Official title**: Directive (EU) 2024/1760 of the European Parliament and of the Council of 13 June 2024 on corporate sustainability due diligence and amending Directive (EU) 2019/1937 and Regulation (EU) 2023/2859
- **CELEX**: [32024L1760](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024L1760) · amended by [32025L0794](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500794) and [32026L0470](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202600470)
- **OJ**: OJ L, 2024/1760, 5.7.2024 · amended by OJ L, 2025/794, 16.4.2025 and OJ L, 2026/470, 26.2.2026
- **In force**: **25 July 2024**, the twentieth day after publication · Directive (EU) 2026/470 in force **18 March 2026**, also the twentieth day after publication
- **Transposition**: By **26 July 2028** (Article 37(1) as replaced by Directive (EU) 2026/470)
- **Applies**: From **26 July 2029** · Article 16 reporting for financial years starting on or after **1 January 2030**
- **Scope**: EU companies with more than 5,000 employees and EUR 1.5 billion net worldwide turnover · non-EU companies with more than EUR 1.5 billion net turnover in the Union · ultimate parent companies · franchisors and licensors above the royalty thresholds
- **Supervisor (NL)**: The draft Dutch bill designates the **ACM**
- **Dutch implementing act**: Draft *Wet internationaal verantwoord ondernemen* (Wivo): second consultation closed 3 August 2026; ACM feasibility and enforceability test published 1 October 2026; no submission to the Tweede Kamer found as at 13 October 2026

## What changed between 2024 and 2026?

Two amending directives rewrote the timetable and the scope. [Directive (EU) 2025/794](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500794), in force since 17 April 2025, moved the transposition deadline to 26 July 2027 and the first application dates back by a year. Directive (EU) 2026/470 then moved them again and cut the Directive down to its present size.

| Topic | As adopted in 2024 | Now |
| --- | --- | --- |
| EU companies in scope | More than 1,000 employees and EUR 450 million net worldwide turnover | More than 5,000 employees and EUR 1.5 billion net worldwide turnover |
| Non-EU companies in scope | More than EUR 450 million net turnover in the Union | More than EUR 1.5 billion net turnover in the Union |
| Franchising and licensing | Royalties above EUR 22.5 million and turnover above EUR 80 million | Royalties above EUR 75 million and turnover above EUR 275 million |
| Transposition deadline | 26 July 2026 | 26 July 2028 |
| First application | 26 July 2027 for the largest companies, 26 July 2028 for companies above 3,000 employees and EUR 900 million, 26 July 2029 for the rest | One date, 26 July 2029, for the companies still in scope |
| Article 16 reporting | Staged by group, starting with financial years from 1 January 2028 | Financial years starting on or after 1 January 2030 |
| Penalties (Article 27(4)) | Maximum limit of at least 5 % of net worldwide turnover | Maximum limit set at 3 % of net worldwide turnover |
| Civil liability (Article 29) | Union-wide liability for breaches of Articles 10 and 11 | Article 29(1) deleted; liability under national law with a right to full compensation |
| Climate transition plan (Article 22) | Plan for climate change mitigation required | Article 22 deleted |
| Monitoring (Article 15) | Assessments at least every 12 months | At least every 5 years, and after a significant change |
| Commission reviews (Article 36) | Financial-sector report by 26 July 2026; implementation report by 26 July 2030, then every three years | Financial-sector report deleted; implementation report by 26 July 2031, then every five years |

> **Our analysis: Who gained time, and who left**
>
> Comparing Article 37(1) as adopted with Article 37(1) as replaced gives a plain result. The transposition deadline and the first application date each moved back exactly two years, from 26 July 2026 to 26 July 2028 and from 26 July 2027 to 26 July 2029. The last date in the 2024 timetable, 26 July 2029, did not move. So the largest companies gain two years, while companies between 1,000 and 5,000 employees, or between EUR 450 million and EUR 1.5 billion in turnover, drop out. A company with 6,000 employees and EUR 1.2 billion in turnover was in scope under the 2024 text and is not now, because both thresholds must be met.

## Who is in scope?

### EU companies

An EU company is in scope when it had more than 5,000 employees on average and a net worldwide turnover above EUR 1.5 billion in the last financial year for which accounts have been or should have been adopted (Article 2(1)(a)). The ultimate parent company of a group that reaches those figures is in scope as well (Article 2(1)(b)). Franchisors and licensors are caught when royalties in the Union exceeded EUR 75 million and the company or its group had net worldwide turnover above EUR 275 million (Article 2(1)(c)).

### Non-EU companies

A company formed under the law of a third country is in scope when it generated net turnover above EUR 1.5 billion in the Union in the financial year before the last financial year (Article 2(2)(a)). The same parent and franchising rules apply as for EU companies. Its supervisor is the one in the Member State where it has a branch (Article 24(3)).

### Who is outside

Alternative investment funds and UCITS are excluded (Article 2(8)). A company below the thresholds has no duties of its own under the Directive.

### Banks, insurers and asset managers

A regulated financial undertaking is in scope when it meets the thresholds. Recital 26 of the Directive says that for these firms only the upstream part of the chain of activities is covered, so the clients that receive their services fall outside it. The Commission report on further requirements for the financial sector, which Article 36(1) set for 26 July 2026, no longer exists: Directive (EU) 2026/470 deleted the paragraph.

## What does the CSDDD require?

*Articles 5 and 7*

### Policy and risk management

Companies integrate due diligence into their policies and risk management systems and keep a due diligence policy.

*Article 8*

### Identify and assess

Companies scope their own operations, their subsidiaries and their business partners to find the general areas where adverse impacts are most likely, using reasonably available information (recital 39 of Directive (EU) 2026/470). They are not required to identify impacts systematically at entity level.

*Article 9*

### Prioritise

Where not every impact can be addressed at once, a company may prioritise. Since 2026, not addressing a less significant impact does not by itself expose a company to penalties under Article 27 (Article 9(4)).

*Articles 10 to 12*

### Prevent, end and remediate

Companies prevent potential impacts, bring actual ones to an end and remediate them. As a last resort, for an impact that cannot be prevented or ended, a company stops entering new relationships with the partner concerned or extending existing ones, adopts an enhanced action plan and, where the governing law allows, suspends the relationship (Articles 10(6) and 11(7)).

*Articles 13 and 14*

### Engage and handle complaints

Companies consult stakeholders at set stages of the process and run a notification mechanism and a complaints procedure.

*Articles 15 and 16*

### Monitor and report

Companies assess their measures at least every five years, after a significant change, and whenever there are reasonable grounds to think the measures no longer work (Article 15). Each year they publish a statement on their website within 12 months of the balance sheet date, unless Article 16(2) exempts them, for financial years starting on or after 1 January 2030 (Article 16(1)).

## The dates

### 2024

- **5 July 2024 · Set by law**: Directive (EU) 2024/1760 published in the Official Journal
- **25 July 2024 · Calculated**: Directive (EU) 2024/1760 enters into force

  Article 38: the twentieth day after publication.

### 2025

- **16 April 2025 · Set by law**: Directive (EU) 2025/794 published: transposition moved to 26 July 2027
- **17 April 2025 · Calculated**: Directive (EU) 2025/794 enters into force

  Article 4: the day following publication.
- **16 December 2025 · Set by the European Parliament**: Parliament adopts its position on the Omnibus I directive

### 2026

- **24 February 2026 · Set by law**: Directive (EU) 2026/470 adopted by Parliament and Council
- **26 February 2026 · Set by law**: Directive (EU) 2026/470 published in the Official Journal
- **18 March 2026 · Calculated**: Directive (EU) 2026/470 enters into force

  Article 6: the twentieth day after publication.
- **3 August 2026 · Set by the Ministry of Foreign Affairs**: Second Dutch consultation on the adjusted draft Wivo closes
- **1 October 2026 · Set by the ACM**: ACM publishes its feasibility and enforceability test of the draft Wivo

  The test is dated 17 September 2026.

### 2027

- **26 July 2027 · Set by law**: Commission adopts guidelines under Article 19(2), points (a), (d) and (e), and guidance on model contractual clauses (Article 18)

### 2028

- **26 July 2028 · Set by law**: Member States adopt and publish national measures (Article 37(1)) and tell the Commission which supervisory authorities they designated (Article 24(7))
- **26 July 2028 · Set by law**: Commission adopts guidelines under Article 19(2), points (f) and (g)

### 2029

- **31 March 2029 · Set by law**: Commission adopts delegated acts on the content and criteria for Article 16 reporting
- **26 July 2029 · Set by law**: Member States apply the national measures (Article 37(1))

### 2030

- **1 January 2030 · Set by law**: Article 16 reporting applies for financial years starting on or after this date
- **31 December 2030 · Set by law**: Member States designate a collection body for the European single access point (Article 17(3))

### 2031

- **1 January 2031 · Set by law**: Companies submit the Article 16 annual statement to the collection body for the European single access point (Article 17(1))
- **26 July 2031 · Set by law**: Commission reports on the implementation of the Directive, then every five years (Article 36(2))

### Without an official date

- **No official date · Proposed (draft Wivo)**: The Dutch Wet internationaal verantwoord ondernemen enters into force

  The draft bill sets no date. The Directive requires national measures to be adopted and published by 26 July 2028.

## How is the CSDDD enforced, and what do fines and liability look like?

Each Member State designates one or more supervisory authorities (Article 24(1)). For an EU company the competent authority is that of the Member State of its registered office (Article 24(2)). The authorities can require information and carry out investigations on compliance with Articles 7 to 16 (Article 25(1)). Member States must tell the Commission which authorities they designated by 26 July 2028 (Article 24(7)).

Pecuniary penalties are based on net worldwide turnover. Member States must set the maximum limit at 3 % of the net worldwide turnover of the company in the financial year before the decision, or 3 % of consolidated worldwide turnover for an ultimate parent company (Article 27(4)). The 2024 text set a floor instead of a cap: the maximum limit had to be at least 5 % (Article 27(4) as adopted).

Civil liability changed in the same round. Article 29(1), the Union-wide liability regime for breaches of Articles 10 and 11, is deleted. Article 29(2) remains. Where a company is held liable under national law for damage caused by a failure to meet the due diligence requirements, the injured person has a right to full compensation, and compensation must not lead to overcompensation through punitive, multiple or other damages.

> **What we could not establish: What we could not establish**
>
> We have read the Dutch government's consultation page and the ACM's test of the draft Wivo, but not the text of the adjusted draft. We therefore do not know which penalty level the draft sets now that the Directive caps fines at 3 %. We found no sign that the bill has been submitted to the Tweede Kamer as at 13 October 2026. We have not checked how other Member States are transposing the Directive.

## The Netherlands: where does the implementing bill stand?

Dutch law has no CSDDD statute yet. The Ministry of Foreign Affairs is preparing the *Wet internationaal verantwoord ondernemen* (Wivo). After Omnibus I changed the Directive, the ministry adjusted the draft and ran a [second, short consultation](https://www.internetconsultatie.nl/wivo2/b1) that closed on 3 August 2026. It asked respondents to comment only on the changed passages, and said it limits the bill to the rules the Directive requires.

The draft names the ACM as supervisor. It designates the court in Rotterdam and the College van Beroep voor het bedrijfsleven as the competent administrative courts, and it adds extra rules for enforcing some obligations through civil law.

The ACM published its [feasibility and enforceability test](https://www.acm.nl/nl/publicaties/uht-ontwerpwetsvoorstel-internationaal-verantwoord-ondernemen) on 1 October 2026, dated 17 September 2026. It concludes that the bill is feasible and enforceable if four conditions are met. As at 13 October 2026 that page still describes a draft bill. The Directive requires adoption and publication of the national measures by 26 July 2028.

## What has changed?

**1 October 2026.** The ACM published its feasibility and enforceability test of the draft Wivo, decided on 17 September 2026.

**3 August 2026.** The second consultation on the adjusted draft Wivo closed.

**18 March 2026.** Directive (EU) 2026/470 entered into force, twenty days after its publication on 26 February 2026. It was adopted on 24 February 2026.

**17 April 2025.** Directive (EU) 2025/794 entered into force the day after its publication on 16 April 2025. It moved the transposition deadline to 26 July 2027.

## Check your group against the Article 2 thresholds

Book a working session and we will test your entities against the Article 2 thresholds, naming the article and the source for each conclusion.

- [Book a working session](https://gencompl.ai/contact)

## Questions and answers

### Is my company in scope of the CSDDD?

An EU company is in scope if it had more than 5,000 employees on average and net worldwide turnover above EUR 1.5 billion in the last financial year with adopted accounts, or if it is the ultimate parent of a group that reaches those figures. A non-EU company is in scope if it generated more than EUR 1.5 billion in net turnover in the Union. Franchisors and licensors have separate royalty thresholds under Article 2.

### When does the CSDDD apply?

Member States apply their national measures from 26 July 2029, under Article 37(1) as replaced by Directive (EU) 2026/470. The reporting measures under Article 16 apply for financial years starting on or after 1 January 2030. The earlier dates of 26 July 2027 and 26 July 2028 no longer apply.

### What is the transposition deadline, and has the Netherlands met it?

The deadline is 26 July 2028, so it has not passed. As at 13 October 2026 the Dutch implementing law is a draft bill, the Wet internationaal verantwoord ondernemen, and we found no sign that it has been submitted to the Tweede Kamer.

### Does the CSDDD apply to banks, insurers and asset managers?

A regulated financial undertaking is in scope when it meets the Article 2 thresholds. Recital 26 states that only the upstream part of its chain of activities is covered. Alternative investment funds and UCITS are excluded by Article 2(8).

### Does the CSDDD still require a climate transition plan?

No. Article 22, which required a transition plan for climate change mitigation, was deleted by Article 4(16) of Directive (EU) 2026/470.

### What is the maximum fine under the CSDDD?

Member States must set the maximum limit of pecuniary penalties at 3 % of the net worldwide turnover of the company in the preceding financial year (Article 27(4)). For an ultimate parent company the base is consolidated worldwide turnover.

### Can a company be sued under the CSDDD?

The Union-wide liability regime in Article 29(1) was deleted in 2026. Liability now arises under national law. Where a company is held liable for damage caused by a failure to meet the due diligence requirements, the injured person has a right to full compensation without overcompensation (Article 29(2)).

### Does the CSDDD affect companies below the thresholds?

Not directly, because the duties fall on companies above the thresholds. A smaller company can still be a business partner in the chain of activities of a company in scope, which then has to assess its own operations, its subsidiaries and its business partners.

## Sources

- [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401760) (EUR-Lex · 5 July 2024)
- [Directive (EU) 2025/794 as regards the dates from which Member States are to apply certain requirements](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500794) (EUR-Lex · 16 April 2025)
- [Directive (EU) 2026/470 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202600470) (EUR-Lex · 26 February 2026)
- [Corporate sustainability due diligence](https://commission.europa.eu/topics/business-and-industry/doing-business-eu/sustainability-due-diligence-responsible-business/corporate-sustainability-due-diligence_en) (European Commission)
- [Consultatie Wet internationaal verantwoord ondernemen](https://www.internetconsultatie.nl/wivo2/b1) (Overheid.nl)
- [UHT ontwerpwetsvoorstel Internationaal Verantwoord Ondernemen](https://www.acm.nl/nl/publicaties/uht-ontwerpwetsvoorstel-internationaal-verantwoord-ondernemen) (ACM · 1 October 2026)

## Related content

### Glossary term

- [Net turnover](https://gencompl.ai/glossary/net-turnover-csddd): The ‘net turnover’, as defined in Article 2, point (5), of Directive 2013/34/EU; or, where the company applies international accounting standards adopted on the basis of Regulation (EC) No 1606/2002 or is a company within the meaning of point (a)(ii), the revenue as defined by or within the meaning of the financial reporting framework on the basis of which the financial statements of the company are prepared.
- [Authorised representative (CSDDD)](https://gencompl.ai/glossary/authorised-representative-csddd): A natural or legal person resident or established in the Union that has a mandate from a company within the meaning of point (a)(ii) to act on its behalf in relation to compliance with that company’s obligations pursuant to this Directive.
- [Industry or multi-stakeholder initiative](https://gencompl.ai/glossary/industry-or-multi-stakeholder-initiative): A combination of voluntary due diligence procedures, tools and mechanisms, developed and overseen by governments, industry associations, interested organisations, including civil society organisations, or groupings or combinations thereof, that companies may participate in in order to support the implementation of due diligence obligations.
- [Independent third-party verification](https://gencompl.ai/glossary/independent-third-party-verification): Verification of the compliance by a company, or parts of its chain of activities, with human rights and environmental requirements resulting from this Directive by an expert that is objective, completely independent from the company, free from any conflicts of interest and from external influence, has experience and competence in environmental or human rights matters, according to the nature of the adverse impact, and is accountable for the quality and reliability of the verification.
- [Remediation](https://gencompl.ai/glossary/remediation-csddd): Restoration of the affected person or persons, communities or environment to a situation equivalent or as close as possible to the situation they would have been in had an actual adverse impact not occurred, in proportion to the company’s implication in the adverse impact, including by financial or non-financial compensation provided by the company to a person or persons affected by the actual adverse impact and, where applicable, reimbursement of the costs incurred by public authorities for any necessary remedial measures.
- [Appropriate measures](https://gencompl.ai/glossary/appropriate-measures-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.
- [Risk factors](https://gencompl.ai/glossary/risk-factors-csddd): 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.
- [Stakeholders](https://gencompl.ai/glossary/stakeholders-csddd): The company’s employees, the employees of its subsidiaries and of its business partners, and their trade unions and workers’ representatives, and individuals or communities whose rights or interests are or could be directly affected by the products, services and operations of the company, its subsidiaries and its business partners and the legitimate representatives of those individuals or communities.
- [Severity of an adverse impact](https://gencompl.ai/glossary/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.
- [Severe adverse impact](https://gencompl.ai/glossary/severe-adverse-impact): An adverse impact that is especially significant on account of its nature, such as an impact that entails harm to human life, health or liberty, or on account of its scale, scope or irremediable character, taking into account its gravity, 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.
- [Adverse human rights impact](https://gencompl.ai/glossary/adverse-human-rights-impact): An impact on persons resulting from an abuse of one of the human rights listed in Part I, Section 1, of the Annex to this Directive, as those human rights are enshrined in the international instruments listed in Part I, Section 2, of the Annex to this Directive; or an abuse of a human right not listed in Part I, Section 1, of the Annex, but enshrined in the human rights instruments listed in Part I, Section 2, of the Annex, provided that the three conditions of point (c)(ii) are met.
- [Adverse environmental impact](https://gencompl.ai/glossary/adverse-environmental-impact): An adverse impact on the environment resulting from the breach of the prohibitions and obligations listed in Part I, Section 1, points 15 and 16, and Part II of the Annex to this Directive, taking into account national legislation linked to the provisions of the instruments listed therein.
- [Adverse impact](https://gencompl.ai/glossary/adverse-impact-csddd): An adverse environmental impact or adverse human rights impact.
- [Business partner](https://gencompl.ai/glossary/business-partner-csddd): An entity (i) with which the company has a commercial agreement related to the operations, products or services of the company or to which the company provides services pursuant to point (g) (‘direct business partner’); or (ii) which is not a direct business partner but which performs business operations related to the operations, products or services of the company (‘indirect business partner’).
- [Chain of activities](https://gencompl.ai/glossary/chain-of-activities): Activities of a company’s upstream business partners related to the production of goods or the provision of services by that company, including the design, extraction, sourcing, manufacture, transport, storage and supply of raw materials, products or parts of products and the development of the product or the service; and activities of a company’s downstream business partners related to the distribution, transport and storage of a product of that company, where the business partners carry out those activities for the company or on behalf of the company, and excluding the distribution, transport and storage of a product that is subject to export controls under Regulation (EU) 2021/821 or to the export controls relating to weapons, munitions or war materials, once the export of the product is authorised.