EU Directive on corporate sustainability due diligence published in OJEU

The text of the directive is available in all EU languages (click here).

The CSDDD entered into force 20 days later, on 25 July. On the same date, the European Commission also published an FAQ on the new directive. There are now no barriers to transposing the directive into national law; this must happen by 26 July 2026 at the latest.

The implementation schedule for the CSDDD is as follows:

• from 26 July 2027, i.e. three years after the Directive comes into force:

   • EU companies and groups with more than 5,000 employees on average and global net turnover of more than €1,500m over the last financial period preceding 26 July 2027, with the exception of the measures necessary to comply with Article 16, concerning the disclosure of an annual statement on topics covered by the CSDDD, which Member States shall apply to those companies for financial years starting on or after 1 January 2028;

    • non-EU companies and groups with net turnover in the EU of more than €1,500m;

• from 26 July 2028, i.e. four years after the Directive comes into force:

    • EU companies and groups with more than 3,000 employees on average and global net turnover of more than €900m over the last financial period preceding 26 July 2028, with the exception of the measures necessary to comply with Article 16, concerning the disclosure of an annual statement on topics covered by the CSDDD, which Member States shall apply to those companies for financial years starting on or after 1 January 2029;

   • non-EU companies and groups with net turnover in the EU of more than €900m;

• from 26 July 2029: all other companies that fall within the scope of the CSDDD. Readers will remember that this scope includes: (i) EU companies (or groups) with more than 1,000 employees on average, and global net turnover of more than €450m; (ii) companies (or groups) that have entered into franchising or licensing agreements in the EU in exchange for royalties received from independent third-party companies of more than €22.5m in the EU, provided that the company had global net turnover of more than €80m; (iii) non-EU companies (or groups) with net turnover in the EU of more than €450m; and (iv) non-EU companies (or groups) that have entered into franchising or licensing agreements in the EU in exchange for royalties received from independent third-party companies of more than €22.5m in the EU, provided that the company had net turnover in the EU of more than €80m.

According to the FAQ mentioned above, the CSDDD is expected to apply to around 6,000 EU companies (or groups) and around 900 non-EU companies (or groups).

It should be noted that SMEs do not fall within the scope of the CSDDD. However, if they form part of the value chain of companies within the scope of the CSDDD, they may be asked to share information on their adverse actual or potential impacts, and to address those in line with the obligations of the company within the scope of the CSDDD.