What is actually changing with the CSDDD?

The EU’s sustainability regulations do not operate in isolation. The Corporate Sustainability Due Diligence Directive (CSDDD) overlaps with the European Sustainability Reporting Standards (ESRS), the Corporate Sustainability Reporting Directive (CSRD), the Forced Labour Regulation, the Deforestation Regulation (EUDR), and more. This means the changes to these regulations introduced by the omnibus packages also overlap, especially across due diligence, reporting, and product-level obligations.

The practical question for companies is now “what to prepare for?”

Some obligations have been softened or delayed, while others remain fully in force. Implementing against outdated text, or addressing each regulation alone, is now a real cost risk.

Key changes and what companies need to know

Thresholds have changed: The CSDDD applies to fewer companies than the CSRD, so companies need to know if they fall within the scope of one, both, or neither. Keep in mind that the original thresholds could be reintroduced following the Commission’s review in 2031.

Don’t jettison transition planning: The climate transition plan requirement has been removed from the CSDDD entirely, but companies in-scope of the CSRD are still required to disclose transition plans against the ESRS.

Prepare for supply-chain data requests: Both the CSRD and CSDDD limit value-chain information requests to reduce burdens on smaller companies. The CSRD cap applies to undertakings with up to 1,000 employees, while the CSDDD restricts requests to necessary information for business partners with fewer than 5,000 employees, where information cannot reasonably be obtained elsewhere. Companies should ensure requests comply with the relevant regime.

Understand that the CSDDD does not override other regulations: The CSDDD’s requirements do not overrule or replace sector specific requirements, including the Conflict Minerals Regulation, the Battery Regulation, and the EUDR, which have their own thresholds, due diligence procedures, and timelines.

Be aware that timelines have shifted considerably: Companies need to ensure the coming deadlines don’t sneak up on their compliance teams.

Keep an eye out for more changes: Organizations need to watch out for the updated Sustainable Finance Disclosure Regulation (SFDR 2). They also need to understand how member states are using their gold-plating powers (i.e. how member states can add or strengthen non-core requirements at their discretion beyond the CSDDD’s minimum requirements, which must be transposed into national law.)

How we can help

Our CSDDD Support Package is designed to help your company prepare for the CSDDD and understand what you need to do, and when.

The package includes:

• A rule map that translates the amended CSDDD into concrete action items, clearly marking what changed under the omnibus, what you need to do now, and what can wait. Additionally, the rule map doubles as a CSDDD compliance gap assessment and a implementation tracker, so it supports you from planning through to review.
• A comparative assessment against the United Nations Guiding Principles on Business and Human Rights (UNGPs), OECD Due Diligence Guidance for Responsible Business Conduct, the French and German supply chain acts, and related EU regimes (CSRD, EUDR, Forced Labour Regulation, Batteries Regulation, SFDR, EU Taxonomy), so you can leverage work you may already have done.
• An overview of national transposition laws in the 10 largest EU markets as they are released, ahead of the CSDDD’s July 2028 transposition deadline.
• Direct access to our legal experts.

If you’re interested to know more about how our CSDDD package can help you navigate these changes, contact us at info@ecofact.com