Corporate sustainability due diligence

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Corporate sustainability due diligence

Prepare for the EU Corporate Sustainability Due Diligence Directive

The Directive requires large companies to identify and address adverse impacts on human rights and the environment in their own operations, their subsidiaries and their chains of activities. We help companies and their business partners understand what applies to them, when, and how to prepare.

Legal actDirective (EU) 2024/1760
In force since25 July 2024
Amended byOmnibus I: Directive (EU) 2025/794 (postponement) and Directive (EU) 2026/470 (substantive changes, in force since 18 March 2026)
Applies from26 July 2029

Who is covered

Very large companies, inside and outside the EU

Following the Omnibus I simplification, the Directive applies only to the largest companies. Thresholds include consolidated figures where a company is the ultimate parent of a group.

EU companies5,000+ employees
and €1.5 bn turnover

Companies and partnerships formed under the law of a Member State, with net worldwide turnover of at least EUR 1.5 billion.

Non-EU companies€1.5 bn turnover
in the EU

Companies from third countries that generate a net turnover of at least EUR 1.5 billion in the Union.

Franchising and licensingRoyalty-based
business models

Companies with franchising or licensing agreements in the EU can also be covered where the royalty and turnover thresholds are met.

SMEs are not covered, but they will feel the effects

Micro, small and medium-sized companies are outside the scope. However, as suppliers and partners of large companies they may receive requests for information and contractual commitments. The Directive protects them by limiting such information requests and through guidance and voluntary model contractual clauses.

What companies must do

A risk-based due diligence process

Companies in scope must build due diligence into their policies and risk management. After Omnibus I, they can focus on the areas where adverse impacts are most likely and most severe, based on reasonably available information.

  • Identify and assess actual and potential adverse impacts on human rights and the environment.
  • Prevent, mitigate and end those impacts, or minimise them where they cannot be ended immediately.
  • Complaints and notifications: set up a procedure through which concerns can be raised.
  • Monitor the effectiveness of the measures taken.
  • Communicate publicly on due diligence.
  • Bear the costs of setting up and running the process, without passing them unfairly to smaller partners.

Enforcement and liability

Supervision in every Member State

National authorities

Each Member State designates an authority to supervise and enforce the rules, including through injunctive orders.

Fines up to 3%

Penalties for the most serious breaches are capped at 3% of the company’s net worldwide turnover.

European network

The Commission will set up a European Network of Supervisory Authorities to coordinate enforcement.

Civil liability

Where a company is held liable under national law for damage caused by non-compliance, affected persons have a right to full compensation.

Timeline

Key dates after Omnibus I

  1. 26 July 2027The Commission publishes its main guidelines.
  2. 26 July 2028Deadline for Member States to adopt and publish transposition measures. Further Commission guidelines.
  3. 26 July 2029National rules start to apply to companies in scope.
  4. 1 January 2030Reporting under Article 16 applies for financial years starting on or after this date.

How we help

From scope check to national transposition

The Directive will apply through national laws, which may differ between Member States. We follow its transposition and help you prepare in time.

  1. 01
    Scope assessmentWhether your company or group falls within the Directive after the Omnibus changes.
  2. 02
    Gap analysisA review of your current policies, risk management and supplier processes against the new obligations.
  3. 03
    Contracts with business partnersContractual clauses for your value chain, including support for SME suppliers receiving requests from large customers.
  4. 04
    Transposition monitoringHow each Member State implements the Directive, using our EU law implementation methodology.

Official sources

European Commission: Corporate sustainability due diligence Directive (EU) 2024/1760 on EUR-Lex

Information reflects the Commission’s overview as amended by Omnibus I. Last checked: November 2026.

Contact

Not sure whether the Directive applies to you?

Tell us about your company or your largest customers. We will assess your position and next steps.