Money & markets
Directive (EU) 2024/1760
CSDDD
Corporate Sustainability Due Diligence Directive
The biggest companies must look for human-rights and environmental harm in their chains — and fix what they find, not just write a policy.
Does this hit me?
The aim is fewer hidden harms in clothes, gadgets, and food. You do not get a new personal duty.
Check in the wizardPick a country in the header to see who enforces this at home. Union text is not the last word for directives.
Next switch-on: in 10 months · 26 Jul 2027 — CSDDD — first wave for the largest groups
How it rolls in
Jul 2024
Entered into force.
2027+
First application for the largest companies.
Why it exists
Reporting (CSRD) describes problems. Due diligence is supposed to prevent them: child labour, pollution, land grabs further down the chain.
What actually changes
- Identify and address adverse impacts in operations, subsidiaries, and chains of activities.
- Climate transition plans are part of the package.
- Civil liability exists in defined cases.
- SMEs are not the main addressees, but large buyers will cascade questions.
How it hits you
The aim is fewer hidden harms in clothes, gadgets, and food. You do not get a new personal duty.
For citizens
What this does to everyday life
Rights, bills, and what you can ignore. You are usually not the one who files — companies and states are.
The clothes and gadgets chain
The biggest companies must look for labour and environmental harm upstream and fix what they find. You should, over years, see fewer 'cheap because someone else paid' products — or louder fights about them.
Rights you actually get
- National law will set how victims can claim. This is not an app button; it is courts and NGOs.
Costs and trade-offs
- Some products get dearer if exploitation was the margin.
What you can do
- Support complaints mechanisms and unions in producer countries; boycotts are optional, due diligence is the legal idea.
What you can ignore
- You are not required to audit a factory from your sofa.
If something goes wrong
National CSDDD supervisory authority once designated; civil claims through national courts.
More citizen notes across files: For people
Heard this? Not quite.
Claim: EU firms must police the entire planet overnight.
Duties are risk-based and phased by size. You prioritize severe, likely harms — not a perfect map of every screw.
Latest official statements
All EU NewsNo tagged Commission, Parliament or Council statement in the current feeds.
Board one-pager
Board one-pager
Who this is for: EU finance, trade and reporting teams. Directive (EU) 2024/1760. in 10 months · 26 Jul 2027.
Scope
- You meet the high employee and turnover thresholds (phased from 2027 for the largest).
First 90 days
- Year -1: Map high-risk geographies and commodities, not every SKU.
- Year -1: Align CSDDD with existing CSRD / EUDR / forced-labour files so suppliers get one ask.
Penalties: Administrative penalties under national law (turnover-based in the directive's design) plus civil liability in scoped cases.
For companies
How to stay on the right side of this file
Practical order of work, not a substitute for counsel. Very large companies, phased by size; duties cascade through contracts.
You are probably
Very large companies, phased by size; duties cascade through contracts.
Effort
A scoped programme this year beats a scramble at the apply-date.
Budget
SME: owner time plus one honest vendor. Large: a named lead, not a taskforce slide.
Roles in this file
The same company can wear more than one hat. Classify before you buy a tool.
Sourcing + human rights
This pack names Sourcing + human rights as an owner of early work.
Map high-risk geographies and commodities, not every SKU.
Compliance
This pack names Compliance as an owner of early work.
Align CSDDD with existing CSRD / EUDR / forced-labour files so suppliers get one ask.
Are you in scope?
Build toward- You meet the high employee and turnover thresholds (phased from 2027 for the largest).
Usually not, if
- SMEs as direct addressees — they still feel buyer codes and cut-offs.
First moves
- Year -1Map high-risk geographies and commodities, not every SKU.Sourcing + human rights
- Year -1Align CSDDD with existing CSRD / EUDR / forced-labour files so suppliers get one ask.Compliance
- Ask large buyers which evidence they actually need. One shared pack beats five portals.
If you skip this
- Cutting a supplier without trying to fix harm — that can make impacts worse.
Done looks like
- Risk mapping.
- Prevention/corrective action plans.
- Complaints mechanism logs.
- Climate transition plan.
Keep this evidence
- Risk mapping.
- Prevention/corrective action plans.
- Complaints mechanism logs.
- Climate transition plan.
Ask vendors
- Where are the highest-risk tiers for labour and environment, and what have you remedied in the last 24 months?
Where programmes usually break
- Cutting a supplier without trying to fix harm — that can make impacts worse.
Call counsel when
- Administrative penalties under national law (turnover-based in the directive's design) plus civil liability in scoped cases.
- A supervisor letter, a dawn information request, or a deal that warrants this file.
Enforcement
Administrative penalties under national law (turnover-based in the directive's design) plus civil liability in scoped cases.
National supervisory authorities designated by Member States.
Need a stack, not one file? Open the company desk
Professional briefing
Legal architecture and duties
For counsel, compliance, and policy teams. Not advice. The Official Journal still wins.
- Instrument
- Directive
- Legal basis
- Arts 50, 114 TFEU · Directive (EU) 2024/1760, as affected by Omnibus I timing/scope changes
- Application
- Entered into force July 2024. Original transposition 26 July 2026, with staggered application from 2027. Omnibus I (2026) postponed and narrowed parts of the file — confirm the consolidated dates before you budget a programme.
A corporate duty to identify, prevent, mitigate and remediate adverse human-rights and environmental impacts in the chain of activities, plus a climate transition plan aligned with the Paris Agreement. It is risk-based, not a certificate for every SKU. Civil liability and administrative supervision are the teeth. SMEs are usually not addressees but will receive contractual cascade.
How the file is built
Scope of companies
EU and non-EU companies above employee and turnover tests, with a higher bar for third-country companies. Financial undertakings have a modified chain. Omnibus changes to thresholds must be read in the OJ.
Chain of activities
Upstream is broad; downstream is more limited than campaigners wanted (and more than some industry drafts). Map your business model to the statutory definitions, not to ISO 20400 slides.
Climate plan
A transition plan designed to ensure compatibility with 1.5°C. This is a governance artefact, distinct from CSRD disclosure of the same plan.
Operators
| Role | Who | Core duties |
|---|---|---|
| In-scope company | Meets size tests (EU or non-EU with EU turnover). | Integrate due diligence, identify impacts, prevent/correct, notify, remediate, complaints, monitor, communicate, climate plan. |
| Directors | Oversight of due diligence. | National company law will specify; do not assume a one-size EU directors’ duty. |
| SME supplier | Not the addressee. | Will still see codes, audits, and data requests; the Directive tells large firms to limit the burden. |
Scope
EU companies above thresholds worldwide for the chain of activities; non-EU companies above EU-turnover tests. Impacts outside the Union are in, which is the point.
In
- Human-rights and environmental adverse impacts listed via international instruments in the annexes.
- Own operations, subsidiaries, and chain of activities as defined.
- Climate transition plan.
Out, or narrower than assumed
- Companies below the (amended) size tests.
- The downstream chain is not a full use-phase liability for every product.
- SMEs as duty-holders — they are protected from unreasonable contractual cascading on paper; practice will lag.
Operative provisions
| Anchor | Rule | What it does in practice |
|---|---|---|
| Arts 5–11 | Due-diligence cycle: integration, identification, prevention, bringing to an end, complaints, monitoring, communication. | A static supplier code is not the duty. Prioritisation by severity and likelihood is required. |
| Climate plan | Transition plan compatible with the Paris Agreement. | Align with CSRD/ESRS E1 and with actual capex — inconsistency is a litigation exhibit. |
| Liability / supervision | Administrative supervision plus civil liability for damage caused by an intentional or negligent failure to comply with specified duties. | Causation and the ‘adequate measures’ defence will be the litigation core. |
Secondary law and guidance
- Commission guidelines (due diligence and model contractual clauses) — delayed relative to corporate programmes.
- National supervisory authorities (to be designated).
National layer. Transposition will decide liability procedure, criminal overlays, works-council information, and whether existing duty-of-vigilance (FR) or Lieferkettengesetz (DE) is aligned or duplicated. Dual-compliance is the 2026–28 reality.
How it sits with other files
Disclose the system you actually run. Dual teams that disagree on impacts will be cross-examined together.
Commodity-specific traceability with geolocation is stricter and earlier than CSDDD’s risk-based model. Do not merge them into one weak questionnaire.
Carbon at the border is a customs instrument; CSDDD climate plans are corporate governance. Both can move the same suppliers.
Enforcement and private rights
Who
National supervisory authorities; European network for coordination. Civil courts for liability.
Tools
Orders, periodic penalties, naming, administrative fines (a percentage of worldwide net turnover in the Directive’s frame).
Private rights
Victims and some representative organisations can claim. Limitation periods are set in the Directive as a floor.
Risk register
| Risk | Signal | Control |
|---|---|---|
| Questionnaire cascade without prioritisation | Same 200-question form to every vendor | Severity/likelihood heat map; deeper work on high-risk geographies and commodities. |
| Plan vs capex mismatch | 1.5°C plan, rising fossil capex | Board-level reconciliation with CSRD E1 and financial statements. |
| National dual duty | Ignoring FR/DE statutes because ‘EU file is later’ | Gap analysis against existing national law now. |
Open issues
- Final Omnibus thresholds and application dates.
- How ‘adequate measures’ will be judged for tier-n suppliers.
- Conflict with blocking statutes and state-secret suppliers in defence and energy.
Primary sources
The biggest companies must look for human-rights and environmental harm in their chains — and fix what they find, not just write a policy.
You feel it now
The on-switch is still coming — do not wait for the headline.
Next
Staggered from 2027 for the largest groups
Where it lands
| Channel | People | Companies |
|---|---|---|
| Real remediation, not a code of conduct | The aim is fewer hidden harms in clothes, gadgets, and food. You do not get a new personal duty. | You must identify and address severe human-rights and environmental impacts in chains of activities. Writing a policy is the start, not the end. |
| Civil liability | The aim is fewer hidden harms in clothes, gadgets, and food. You do not get a new personal duty. | In defined cases, failure to due-diligence can underpin claims. That changes how legal and sourcing sit together. |
| Climate plan | The aim is fewer hidden harms in clothes, gadgets, and food. You do not get a new personal duty. | A transition plan aligned with 1.5°C sits in the same file as human-rights due diligence for in-scope companies. |
Who gains
Workers and communities in supply chains; firms already doing due diligence.
Who pays
Very large companies first; suppliers if they must upgrade practices.
Who pays
Very large companies first; suppliers if they must upgrade practices.
Who benefits
Workers and communities in supply chains; firms already doing due diligence.
Read the official text