European UnionAmended
Corporate Sustainability Reporting Directive
Revised reporting standards published on 21 September 2026 and in force from 10 November, with the value chain cap now final.
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Directive requiring large companies to identify and mitigate human rights and environmental risks across their operations and supply chains.
Scope is now 5,000 employees and EUR 1.5 billion turnover, with fines capped at 3 percent; the guidelines consultation closed on 24 July 2026.
In plain language
The Corporate Sustainability Due Diligence Directive requires large European companies, and non-EU companies with substantial turnover in Europe, to carry out due diligence on human rights and environmental risks across their operations and chains of activity. The Omnibus I amendments, published as Directive (EU) 2026/470 and in force since 18 March 2026, narrowed the scope sharply. EU companies are covered only if they have more than 5,000 employees and more than 1.5 billion euros in worldwide net turnover, and non-EU companies only if they generate more than 1.5 billion euros of net turnover in the EU. The directive applies across all sectors rather than to a list of high-risk industries.
The due diligence process requires companies to identify actual and potential adverse impacts on human rights and the environment, prioritise the most severe and likely, take measures to prevent or mitigate them, and provide a complaints mechanism. Companies begin with a scoping exercise based on information that is already reasonably available. Smaller business partners, those with fewer than 5,000 employees, may be asked for information only as a last resort, and any request must be targeted, reasonable and proportionate. The original duty to adopt a climate transition plan was removed by the omnibus.
The EU-wide civil liability regime was also removed, so whether victims can sue now depends on each member state's national law. Supervisory authorities may impose fines capped at 3 percent of net worldwide turnover. Member states must transpose the directive by 26 July 2028, with obligations applying from 26 July 2029. The Commission consulted on its implementation guidelines between 12 June and 24 July 2026, and the guidelines are due by July 2027.
Obligations
Identify, prioritise, prevent and mitigate adverse impacts on human rights and the environment across operations and chains of activity.
Establish a transparent channel for workers, communities and stakeholders to raise concerns about impacts.
Begin with a scoping exercise using information that is already reasonably available, then assess in depth where adverse impacts are most likely and most severe.
Business partners with fewer than 5,000 employees may be asked for information only as a last resort, and any request must be targeted, reasonable and proportionate.
Take corrective action to cease, mitigate or remedy identified adverse impacts.
Disclose due diligence processes and outcomes publicly, generally through sustainability reporting.
Seek contractual assurances from business partners that they will respect due diligence expectations, with appropriate verification.
Timeline
Directive entered into force following publication in the Official Journal.
Commission published the first simplification omnibus proposing significant amendments.
Stop-the-clock directive adopted, moving transposition to July 2027 at that stage.
Political agreement narrowed scope to companies above 5,000 employees and removed the EU-wide civil liability regime.
Omnibus I, Directive (EU) 2026/470, published in the Official Journal.
Amending directive entered into force with the revised calendar
Commission public consultation on the implementation guidelines, covering due diligence practice, risk factors, model contractual clauses, stakeholder engagement and penalties.
Commission guidelines and model contractual clauses due.
Member state transposition deadline.
Obligations apply to in-scope companies.
Changelog
Corrected the scope thresholds (5,000 employees and EUR 1.5 billion turnover, not either one), the penalty cap (3 percent of worldwide turnover), the supplier protection threshold (5,000 employees, not 500) and the enforcement body; removed a scenario analysis duty and a sector limitation the directive does not contain; added the guidelines consultation.
Tracker entry revised to reflect the consolidated omnibus text and updated transposition calendar.
Scope thresholds and civil liability treatment updated following the trilogue outcome.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Coverage
Same jurisdiction
Revised reporting standards published on 21 September 2026 and in force from 10 November, with the value chain cap now final.
Read →Leather left the scope on 18 September 2026, when Delegated Regulation (EU) 2026/2102 entered into force.
Read →Commission adopted its implementation guidelines on 26 June 2026 and launched the Single Portal and risk database on 30 June.
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