Resources · Regulation
The CSDDD requires very large companies to carry out due diligence along their value chain. After Omnibus I it applies above 5,000 employees and EUR 1.5bn turnover — who is covered and what was deleted.
EU Directive (EU) 2024/1760 on mandatory human-rights and environmental due diligence along the value chain.
After Omnibus I, only companies with more than 5,000 employees and more than EUR 1.5bn worldwide net turnover. The original thresholds were 1,000 employees and EUR 450m.
It applies from Jul 26, 2029. Member States transpose the changes into national law by Jul 26, 2028.
The climate transition plan duty (Article 22) and the EU-wide civil liability regime. The due diligence process itself remains.
The Corporate Sustainability Due Diligence Directive requires large companies to run risk-based due diligence on adverse human-rights and environmental impacts — in their own operations and with upstream and downstream business partners. It requires action, not only reporting.
Omnibus I narrowed the scope sharply. Directive (EU) 2026/470 has been in force since Mar 18, 2026.
The due diligence process remains substantially intact and has to be embedded in company policy. What is new is that identified impacts may be prioritised on a risk basis — not everything has to be addressed at once.
This is the largest substantive change. Article 22 of the CSDDD obliged companies in scope to adopt and implement a Paris-aligned climate transition plan. Omnibus I deleted that article. The CSDDD no longer contains a transition plan duty. What remains is the disclosure of an existing plan under the CSRD, specifically ESRS E1-1.
National supervisory authorities check compliance and can impose fines. Omnibus I intervened noticeably in the liability regime.
Three frameworks that are often confused.
After Omnibus I, only companies with more than 5,000 employees and more than EUR 1.5bn worldwide net turnover; for non-EU companies, turnover generated in the EU counts. The directive applies from Jul 26, 2029. Smaller suppliers can remain indirectly affected when large customers pass requirements down by contract.
No. Article 22 of the CSDDD was deleted by Omnibus I. There is no longer an obligation to adopt a climate transition plan. Companies that have one and fall under the CSRD disclose it via ESRS E1-1 — that is a reporting duty, not a duty to act.
Those were the thresholds in the 2024 version. Omnibus I raised them to more than 5,000 employees and more than EUR 1.5bn. The old figures still appear in many articles.
Not because of an EU-wide regime — that was repealed. Where national law already provides for liability, the right to full compensation remains. Fines imposed by supervisory authorities are capped at 3% of worldwide net turnover.
The CSRD requires reporting on sustainability impacts under the ESRS. The CSDDD creates operational duties: prevent, mitigate and remedy adverse impacts — not merely report on them.
It still applies to companies from 1,000 employees in Germany. The annual reporting duty is to be dropped retroactively; the amending act had not been passed as of autumn 2026. In practice the reporting duty is suspended, because BAFA stopped reviewing reports on Nov 7, 2025. The due diligence duties — risk management, risk analysis, measures — remain unchanged.
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