European UnionDelayed
Corporate Sustainability Due Diligence Directive
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.
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The EU sustainability reporting regime requiring double materiality disclosure, now substantially narrowed by the 2025 simplification omnibus.
Revised reporting standards published on 21 September 2026 and in force from 10 November, with the value chain cap now final.
In plain language
The CSRD requires in-scope companies to report against the European Sustainability Reporting Standards on a double materiality basis, covering both the company's impacts on people and planet and the sustainability risks it faces. The first wave of reports was published in 2025.
The 2025 omnibus significantly raised the employee threshold, removed many mid-sized companies from scope, and delayed later reporting waves by two years while the standards themselves are simplified. For suppliers, the value chain disclosures remain the important part: buyers request primary data from suppliers to populate their own reports, and that request cascade continues regardless of the scope changes.
The simplified standards adopted by the Commission on 3 July 2026 cut mandatory datapoints by more than 60 percent and introduce a value chain cap. Companies within the CSRD may not require smaller companies in their value chains, those averaging fewer than 1,000 employees, to provide more information than the voluntary standard covers. The standards cleared the Parliament and Council scrutiny period without objection, were published in the Official Journal on 21 September 2026 and enter into force on 10 November 2026. For most suppliers the cap is the most useful protection the omnibus produced, and it is worth citing when a buyer questionnaire goes beyond it.
Obligations
Companies must assess and disclose both impact materiality and financial materiality across environmental, social and governance topics.
Reporting extends beyond own operations to material impacts in the upstream and downstream value chain, subject to transitional relief.
Sustainability statements require limited assurance, with a pathway towards reasonable assurance over time.
Timeline
Directive entered into force across the European Union.
First wave of CSRD-aligned reports published by the largest listed companies.
Stop-the-clock directive postponed waves two and three by two years.
Political agreement raised the threshold to 1,000 employees and removed the listed SME wave.
Omnibus I published; member states transpose the CSRD provisions by 19 March 2027.
Commission adopted the simplified reporting standards and the voluntary standard, including the value chain cap protecting smaller suppliers.
Revised standards published in the Official Journal after the scrutiny period ended without objection.
Revised standards enter into force.
Revised scope and simplified standards apply for financial years starting on or after this date.
Changelog
Recorded that the revised standards cleared scrutiny, were published on 21 September 2026 and enter into force on 10 November 2026.
Added the simplified reporting standards adopted on 3 July 2026 and the value chain cap; scope thresholds stated precisely.
Entry updated to reflect the revised thresholds and the delayed reporting calendar.
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
Same jurisdiction
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.
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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