CSDDD

CSDDD after Omnibus I: who is still in scope, and from when

The EU's 2026 Omnibus I amendments moved the CSDDD start to 26 July 2029 and raised the thresholds. What changed, what did not, and what suppliers should do now.

By Burag Gurden · · 3 min read

The Corporate Sustainability Due Diligence Directive (CSDDD) has changed more in the past eighteen months than in the two years it took to adopt. With the Omnibus I amendments now final, companies finally have a stable picture of who is in scope and when the obligations apply. Here is what changed, what stayed the same, and what it means if you supply EU companies.

What Omnibus I changed

Omnibus I was published in the Official Journal as Directive (EU) 2026/470 on 26 February 2026 and entered into force on 18 March 2026. For the CSDDD, four changes matter most.

  • Later start, one date for everyone. Member States must transpose the CSDDD by 26 July 2028, and companies in scope apply it from 26 July 2029. The earlier phase-in by company size is gone; there is now a single start date.
  • Fewer companies in scope. The directive now covers EU companies with more than 5,000 employees and more than €1.5 billion in net worldwide turnover, and non-EU companies with more than €1.5 billion net turnover in the EU.
  • No EU-wide civil liability regime. The harmonised EU rules on civil liability were removed. Liability now depends on national law, and Member States keep discretion over how victims are compensated.
  • No mandatory climate transition plan. The obligation to adopt and implement a climate transition plan under the CSDDD has been repealed.

What did not change

The core of the directive is intact. Companies in scope still have to run risk-based due diligence on human rights and environmental impacts in their own operations, their subsidiaries and their chain of activities. In practice that means:

  • identifying and assessing actual and potential adverse impacts;
  • preventing, mitigating or ending them, with remediation where harm has occurred;
  • running a complaints procedure that affected people and organisations can use;
  • engaging with stakeholders and monitoring whether the measures work;
  • reporting publicly on the process.

Fines for non-compliance remain, set and enforced by national supervisory authorities.

If you are a supplier, you are still affected

Most companies that read about the CSDDD are not in scope themselves. They supply companies that are. Raising the thresholds does not change how due diligence reaches you: large buyers will still map their chains of activities, send questionnaires, ask for contractual assurances and, for higher-risk suppliers, ask for audits.

Two things are worth keeping in mind:

  1. Buyers prepare well before 2029. Large companies need time to map suppliers, set up complaints procedures and agree contract clauses, so expect requests to arrive years before the application date.
  2. Other rules apply in parallel. If you supply German companies, the German Supply Chain Act (LkSG) and your customers' own codes of conduct may already apply to you. Check where each customer stands rather than waiting for the CSDDD.

What to do now

You do not need a full CSDDD programme to be ready. Five steps put most suppliers in a strong position:

  1. Know your exposure. List which customers are likely to be in scope and what they have already asked for.
  2. Map your own supply chain. Identify your direct suppliers, the countries and materials involved, and where the obvious human rights and environmental risks sit.
  3. Write down what you already do. Policies, supplier codes, audit results and certifications often exist but are scattered. Buyers want them in one place.
  4. Set up a complaints channel. It is one of the clearest signals of maturity, and your customers will need it to work across their chain.
  5. Prepare for questionnaires. Consistent, evidence-backed answers save time and help you keep or win preferred supplier status.

The bottom line

Omnibus I gave companies more time and narrowed the group that is directly in scope, but it did not remove the expectation that large buyers know and manage the risks in their supply chains. Suppliers that can show solid due diligence early will find the 2029 start date an advantage rather than a deadline.

If you want to know what your customers are likely to ask for, and how to answer with evidence, get in touch. For a quick overview of the regulation, see the CSDDD answer in the FAQ.

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