CSDDD, explained: the Corporate Sustainability Due Diligence Directive
The EU directive puts stricter sustainability requirements on businesses around the world – including a mandate to plan for net zero.
As sustainability legislation continues to expand across the globe, companies are finding themselves subject to ever-stricter ESG reporting requirements.
The latest in this wave of legislation is the Corporate Sustainability Due Diligence Directive, or CSDDD for short. Approved by the EU Council in May 2024, the CSDDD is set to have a large impact on businesses – both in the EU and beyond.
Here’s a breakdown of the CSDDD, what it could mean for your business, and how to prepare for compliance.
What is the CSDDD?
The CSDDD is a European Union directive that establishes legal accountability for businesses concerning environmental and human rights transgressions, both within the EU and globally.
It sets obligations for companies to address actual and potential adverse impacts on human rights and the environment, including those related to their own operations, their subsidiaries, and – vitally – their suppliers.
The CSDDD was first adopted by the European Commission in February 2022. In December 2023, a provisional deal outlined the directive’s scope, clarified liabilities for non-compliant companies, defined penalties, and completed the list of rights and prohibitions that companies should respect. It was approved by the European Commission in March 2024 – after undergoing changes that reduced its scope and extended its timeline for implementation – and its final text was published in July 2024 in the EU Commission’s Official Journal.
By 2027, companies need to be ready to comply with the directive, with larger corporations likely to be the first to adhere.
What the CSDDD means for businesses
Requirements for compliance
The era where businesses could overlook or dismiss their supply chain’s impact is drawing to a close:
To comply with the CSDDD, companies must identify, prevent, mitigate, and account for negative human rights and environmental impacts within their operations, subsidiaries, and value chain.
The directive gives business directors specific obligations to integrate due diligence into corporate strategy and consider the human rights, climate change, and environmental consequences of their decisions.
These reports will be public: companies will need to make their sustainability reports accessible to all, meaning they may face increased scrutiny in ESG performance throughout their operations and value chain.
Large companies will also be required to align their business strategies with the Paris Agreement goal of limiting global warming to 1.5 °C – meaning that these large companies must have a plan for reaching net zero.
Learn what net zero is and how to get your business there
Our article explains what net zero means, why it goes beyond “carbon neutral,” and how your company can achieve it.
Read the article
Opportunities
The CSDDD should not be viewed solely as a regulatory obligation.
Complying with the directive presents several opportunities to companies, including:
- Enhanced customer trust and employee commitment
- Improved risk management
- Better access to finance
In addition, the directive will establish a harmonized – and ideally easier-to-navigate – legal framework in the EU.
These opportunities provide the “carrot” of business benefits for companies that prepare in advance for CSDDD, alongside the “stick” of non-compliance penalties.
Which businesses need to comply with CSDDD
Companies based in the EU will need to comply if they meet the following criteria:
- 1,000+ employees
- A net worldwide turnover of over €450 million
Non-EU companies will also have to comply with CSDDD if they generated €450+ million in net turnover within the European Union.
Penalties for non-compliance with CSDDD
The CSDDD will be enforced through administrative supervision and civil liability.
At the state level, EU Member States will designate authorities to supervise and impose sanctions, including fines and compliance orders.
At the European level, a network of supervisory authorities will ensure coordinated enforcement. Those who are harmed by non-compliant companies will have the right to compensation for damages.
For companies that do not pay fines, the provisional agreement includes injunction measures and considers the company’s turnover when imposing monetary penalties; i.e., up to 5% of the company’s net turnover. Additionally, compliance with the CSDDD may become a criterion for the awarding of public contracts and concessions.
Even businesses not directly subject to the CSDDD may be affected if they have business partners bound by the directive, as they may be required to terminate relationships with partners that have adverse environmental or human rights impacts that cannot be mitigated.
When businesses need to comply by
EU companies
The deadline for EU Member States to transpose the CSDDD into national law is July 26th, 2026. The implementation of the CSDDD will then occur gradually, impacting larger companies first:
- End of July 2027 – companies with 5,000+ employees and €1.5 billion net turnover.
- End of July 2028 – companies with 3,000+ employees and €900 million turnover.
- End of July 2029 – companies with 1,000+ employees and €450 million turnover.
Non-EU companies
Though CSDDD is an European Union legislation, companies that are not based in the EU will still have to comply if they generate a net worldwide turnover of more than €450 million in the EU.
The deadlines for non-EU companies to comply are as follows:
- End of July 2027 – Non-EU companies that generated a net turnover of more than €1.5 billion in the EU, in the last financial year preceding 26 July 2027.
- End of July 2028 – Non-EU companies that generated a net turnover of more than €900 million in the Union, in the last financial year preceding 26 July 2028.
- End of July 2029 – Non-EU companies that generated a net worldwide turnover of more than €450 million in the Union in the last financial year preceding 26 July 2029.
Next steps
While the first reporting deadlines may seem far away, ensuring compliance can be a challenge – and non-compliance could result in significant penalties. Therefore, we recommend that companies should already begin preparing to comply with the CSDDD now.
At Normative, our Climate Strategy Advisors have seen from experience that the sooner a business prepares for upcoming legislation, the smoother the compliance process will be.
This is especially true of legislation which targets the value chain – as the CSDDD does – because modern value chains can have thousands of suppliers scattered all around the globe. Manually parsing these suppliers to collect the needed data would be an enormous task.
Normative’s automated carbon accounting platform accelerates the process of calculating your business’s full climate impact – including that of the suppliers in your value chain.
Jumpstart your CSDDD compliance by booking a demo of Normative to learn how we can help you stay compliant, competitive, and equipped to reach net zero.
Use Normative to account for, report, and reduce your carbon emissions
Normative’s automated features – including One-Click Reporting – accelerate your compliance work.
FAQs
Frequently asked questions about the CSDDD
The CSDDD is part of the EU’s effort to enhance the protection of the environment and human rights – both within the EU and around the world.
The EU’s Corporate Sustainability Reporting Directive (CSRD) focuses on expanding and standardizing sustainability reporting requirements for companies, ensuring they provide detailed information on their environmental and social impacts. In contrast, the Corporate Sustainability Due Diligence Directive (CSDDD) aims to establish rules for companies to identify, prevent, mitigate, and account for adverse environmental and human rights impacts in their operations and value chains. In practice, companies based in or operating in the EU may be subject to both directives. In such a case, the CSDDD will not impose new regulatory requirements for companies that are already subject to the CSRD. The only additional requirement imposed by the CSDDD for companies already subject to the CSRD is for companies to describe how they carry out due diligence as provided for the CSDDD.
The CSDDD will apply to both large EU limited liability companies and non-EU companies that have a significant turnover threshold in the EU.
For companies based in the EU:
- If you have 5,000+ employees and €1.5 billion net turnover, you have to comply by the end of July 2027.
- If you have 3,000+ employees and €900 million turnover, you have to comply by the end of July 2028.
- If you have 1,000+ employees and €450 million turnover, you have to comply by the end of July 2029.
For companies outside of the EU:
- If you have a net turnover of more than €1.5 billion in the EU, you have to comply by the end of July 2027.
- If you have a net turnover of more than €900 million in the EU, you have to comply by the end of July 2028.
- If you have a net turnover of more than €450 million in the EU, you have to comply by the end of July 2029.
The CSDDD was adopted on 24 May 2024, when the EU Council gave final approval to the directive. EU member states now have until July 26th, 2026 to transpose the directive into national law.
