CSDDD after Omnibus I: due diligence duties apply to companies with 5,000+ employees and €1.5bn turnover
Date note: Omnibus I (in force 2026-03-18) raised thresholds and postponed application from 2027 to 2029-07-26; transposition by 2028-07-26
What changes
Only very large companies must run human-rights and environmental due diligence on their own operations and direct business partners. Information requests to SME suppliers are capped at the VSME voluntary standard, and civil liability is left to national law.
Who is affected
Large groups above the thresholds; SMEs only indirectly as suppliers receiving questionnaires and contract clauses.
Sizes: large · Sectors: All sectors
What to do
Large companies: build the due diligence framework, supplier risk mapping and complaints mechanism before 2029. SMEs: expect supplier codes of conduct and VSME-level questionnaires; keep basic policies (labour, environment, anti-corruption) ready so you can answer quickly.
Penalty
Up to 5% of worldwide net turnover (for in-scope companies)
Sources
- Council of the EU – Council signs off simplification of sustainability reporting and due diligence (24 Feb 2026) (www.consilium.europa.eu)
- DLA Piper – CSDDD amendments under Omnibus I finalised (knowledge.dlapiper.com)
Last verified 7 September 2026. Informational only, not legal advice.