CSDDD After Omnibus: Who It Binds and When

Directive (EU) 2026/470, published on 26 February 2026, changed the two things anyone actually needs from the Corporate Sustainability Due Diligence Directive: who it binds and when. The thresholds rose to 5,000 employees and EUR 1.5 billion in net turnover, and application moved to 26 July 2029. If you last read about the CSDDD before 2026, the numbers you remember — 1,000 employees, EUR 450 million — are the old ones.

What the CSDDD is, and why it reads differently from the others

The CSDDD is a company-level duty to run risk-based human rights and environmental due diligence across a company's own operations and its chain of activities. It has the same skeleton as the battery and deforestation rules: identify, assess, act, and be able to show the work.

What makes it read differently is the trigger. Battery due diligence attaches to a product — place a battery on the EU market and Article 48 finds you at any size above the exemption. The EUDR attaches to a commodity. The CSDDD attaches to you: it applies because of how large the company is, regardless of what it sells. That is why a mid-sized manufacturer can be squarely inside the battery rule and nowhere near the CSDDD.

The second difference is legal form, and it is not a technicality. The CSDDD is a directive, not a regulation. It does not apply of its own force; Member States transpose it into national law, and the text that binds a company is the national one. Two countries can implement the same directive with different enforcement, different penalties and different reporting mechanics. Anyone planning against "the CSDDD" without naming a Member State is planning against a summary.

What Omnibus I changed

A threshold that more than triples, plus a postponement, is not a tidy-up. It is a decision that the directly obliged population should be much smaller and should start much later.

What it is not is a decision that the underlying expectations go away. The companies still in scope are the largest buyers in Europe, and they are precisely the customers whose questionnaires reach the most suppliers. Scope shrank; supply chains did not.

The three due diligence regimes side by side

This is the table worth keeping, because the three are routinely discussed as one programme and they have almost nothing in common operationally.

Read across the "applies from" row and the sequencing becomes the useful fact: the deforestation date is first and closest, the battery date is next, and the CSDDD is years behind both. A supplier being asked deforestation questions today is not being asked them because of the CSDDD.

Walkthrough: a component supplier inside an obliged customer's chain

A representative scenario. A supplier with 400 employees and EUR 60 million in turnover sells components into two European groups, both far above the new thresholds. It is nowhere near direct scope and never will be.

What arrives. Not a filing deadline — a questionnaire, and later a contractual clause. The customer must run risk-based due diligence across its chain of activities, and the supplier is in that chain. Its answers become the customer's evidence.

What the supplier can actually control. Three things: knowing who its own suppliers are, having a route by which a complaint can reach someone, and being able to answer an origin question without a three-week internal hunt. None of these are CSDDD-specific. All three are already required by the battery rule if it ships batteries, and by the EUDR if it ships anything on that commodity list.

The counterfactual. Suppose the supplier had read the Omnibus headlines in early 2026, seen "scope cut by most of its population" and concluded the pressure was off. Its own position never depended on being in scope. Its two customers stayed in scope, the questionnaires kept coming, and the deforestation questions arrived on a 2026 date that had nothing to do with the CSDDD at all. The mistake would not have been legal; it would have been reading a change in someone else's obligation as a change in its own workload.

Edge cases

Non-EU parent, EU turnover. The directive reaches companies formed outside the Union through turnover generated in the Union. Incorporation outside Europe is not by itself an answer.

Group versus entity. As with every threshold on this site, the question of which figure is tested — entity or consolidated — decides the outcome. Settle it with the people who consolidate the accounts.

Sector rules arrive first. A company can be outside the CSDDD and inside the battery or deforestation duty at the same time. The earliest binding obligation is the one that sets your timetable, and it is unlikely to be this one.

"We're covered because we do CSRD." Reporting on a risk and doing due diligence about it are different obligations with different evidence. One does not discharge the other.

What did not change

The amendment moved thresholds and dates. It did not replace the underlying model, and reading the headlines as "the CSDDD was gutted" leads to a wrong operational conclusion for anyone supplying a large European customer.

Due diligence under this directive remains risk-based. That is a specific idea rather than a softening: a company is expected to find where the severe risks in its chain of activities actually sit and act there, instead of applying one uniform procedure to every supplier. In practice that concentrates attention on a minority of relationships — and whether you are in that minority depends on what you make and where, not on how large you are.

The chain of activities framing also survived. It reaches upstream to the production of goods and the provision of services, which is exactly where suppliers sit. A company outside direct scope is not outside its customer's chain of activities; scope and chain are different concepts, and only one of them moved.

The consequence for a supplier is that the questionnaires do not stop when the obliged population shrinks. Each remaining in-scope company is very large and sits above a very wide supplier base. Cutting the number of obliged companies reduces the number of senders. It does very little to the number of recipients.

Zoom out: the direction did not change, only the population

It would be easy to read Omnibus I as a retreat. A narrower reading fits the facts better: the EU moved the directly obliged population down and the date back, while leaving in place a set of product-level and commodity-level rules that keep arriving on their own schedule. The battery obligation was postponed and kept. The deforestation obligation was simplified and kept. The CSDDD was narrowed and kept.

For a supplier outside Europe, none of the three is addressed to you and all three reach you the same way — as a customer's question you cannot answer from your existing records. The work that answers all of them is the same work: know your own chain, keep the evidence, and be able to produce it on request. Our EUDR guide covers the nearest deadline, our battery due diligence guide the one after it, and the guide for manufacturers outside the EU how the pressure travels down a chain that no regulation names.

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