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EU due diligence · after Omnibus I

CSDDD: the Corporate Sustainability Due Diligence Directive

The CSDDD makes the EU’s largest companies find and fix human rights and environmental harm across their operations and supply chains.

Omnibus I raised its scope to more than 5,000 employees and €1.5 billion turnover, set one start date of 26 July 2029, and deleted the climate transition plan duty.

Most UK businesses will meet it as suppliers, not as companies in scope.

The basics

What the CSDDD is, and what it is not

The Corporate Sustainability Due Diligence Directive, Directive (EU) 2024/1760, is dated 13 June 2024, was published in the Official Journal on 5 July 2024 and entered into force on 25 July 2024.

It requires companies in scope to identify, prevent, mitigate and bring to an end adverse human rights and environmental impacts in their own operations, their subsidiaries and their “chains of activities”.

It is built on the standards most multinationals already use: the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.

What it adds is legal force, a supervisory authority in every Member State and penalties.

It is a due diligence law, not a reporting standard.

Its reporting sister is the Corporate Sustainability Reporting Directive, covered on our CSRD guide, and the two were amended together by Omnibus I, published on 26 February 2026 and in force from 18 March 2026.

The short answer for UK readers

Most UK companies are not in scope.

The ones that are have more than €1.5 billion of EU turnover.

Many more will receive due diligence questions from EU customers who are in scope.

Scope

Who is in scope after Omnibus I

Omnibus I raised every threshold; recital 37 states it plainly, raising €450 million to €1.5 billion and 1,000 employees to 5,000.

The consolidated Article 2 now reads as follows.

An EU company is in scope if it had more than 5,000 employees on average and net worldwide turnover of more than €1.5 billion in the last financial year (Article 2(1)(a)).

An EU company that does not reach those figures itself is in scope if it is the ultimate parent of a group that reaches them on a consolidated basis (Article 2(1)(b)).

A non-EU company is in scope if it generated more than €1.5 billion of net turnover in the Union in the financial year preceding the last one (Article 2(2)(a)).

Three differences from the EU limb are easy to miss: there is no employee test, the turnover is in the Union rather than worldwide, and it is measured one year earlier.

A franchising and licensing limb catches royalties above €75 million and turnover above €275 million, on the conditions Article 2 sets.

Under Article 2(5) the conditions must be met in two consecutive financial years, and the Directive stops applying when they are missed for each of the last two.

Every limb says “more than”: a company with exactly 5,000 employees is outside the EU limb, and so is one with exactly €1.5 billion of turnover.

Alternative investment funds and UCITS remain outside scope.

Sources: consolidated Directive (EU) 2024/1760 Art 2 · Directive (EU) 2026/470 recital 37. The left column no longer applies.
FigureOriginal 2024 textNow
EmployeesMore than 1,000More than 5,000
Net worldwide turnoverMore than €450 millionMore than €1.5 billion
Franchise royaltiesMore than €22.5 millionMore than €75 million
Franchise turnoverMore than €80 millionMore than €275 million

CSDDD · is the company in scope?

Which company are you testing?

Pick a position and enter the figures

A UK group is caught directly through its EU turnover, or through an EU subsidiary that meets the EU limb on its own figures.

Test each separately.

Rules: Directive (EU) 2024/1760 Arts 2(1), 2(2), 2(5) and 37(1), consolidated 18 March 2026 after Directive (EU) 2026/470.

Every limb says “more than”.

A provisional reading, not legal advice.

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UK angle

Does the CSDDD apply to UK companies?

A UK company is caught directly in two ways.

Through the non-EU limb, if it generates more than €1.5 billion of net turnover in the EU in two consecutive years — in which case it must mandate an authorised representative established in the EU.

Or through an EU subsidiary that meets the EU thresholds on its own figures.

The indirect route matters more for most UK businesses.

An in-scope EU customer must run a risk-based scoping exercise across its chain of activities and, where risks look most likely and most severe, assess them in depth — and that is when UK suppliers get questionnaires.

Omnibus I limits those requests: a company may ask business partners with fewer than 5,000 employees only for information it cannot reasonably obtain by other means.

The UK has no CSDDD equivalent.

The closest domestic duty is the annual modern slavery statement under section 54 of the Modern Slavery Act 2015, explained in the Home Office’s transparency in supply chains guidance.

It applies to an organisation with total turnover of £36 million or more, a threshold set by regulation 2 of SI 2015/1833.

UK sustainability reporting runs through UK SRS S1 and S2, which ask for disclosure, not for due diligence.

The CSRD test that runs in parallel for non-EU groups is on our Article 40a guide.

Obligations

What in-scope companies must do

The core duty is risk-based due diligence.

Omnibus I made the first step a scoping exercise “based solely on reasonably available information”, followed by an in-depth assessment only where adverse impacts are most likely and most severe.

Source: consolidated Directive (EU) 2024/1760.
StepWhat the Directive requires
IntegrateBuild due diligence into policies and risk management systems
IdentifyScope the operations and chains of activities, then assess the highest-risk areas in depth (Art 8(2))
Prevent and mitigateAct on potential impacts, with prevention action plans where needed
Bring to an endStop or minimise actual impacts; suspend a business relationship as a last resort
RemediateProvide remediation where the company caused or jointly caused an actual impact
EngageConsult stakeholders at identification, on action plans and on remediation
ComplaintsRun a notification and complaints procedure
MonitorAssess whether the measures work, proportionately and risk-based
CommunicatePublish an annual statement, unless already reporting under the CSRD

Recital 39 of Omnibus I says companies are not required to systematically identify adverse impacts at entity level.

Omnibus I also replaced mandatory termination with suspension as a last resort, and narrowed who counts as a stakeholder, as Weil’s briefing on the final text sets out.

The in-depth assessment carries its own ordering rules in Article 8(2a).

A company may request information only where it is necessary.

Where several business partners could supply it, the company prioritises, where reasonable, the partner where the impact is most likely to arise.

For a UK supplier that means questions should arrive only once the customer has flagged a high-risk area, and should be about that area.

What changed

What Omnibus I changed

Most CSDDD guidance published before March 2026 describes repealed law.

The left column is history.

Sources: Directive (EU) 2026/470, Art 4 · consolidated Directive (EU) 2024/1760.
AreaOriginal 2024 text (no longer applies)After Omnibus I
Start datesPhased: 2027, 2028, 2029One date for everyone: 26 July 2029
Transition plansArticle 22: adopt and put into effect a planArticle 22 deleted in its entirety
Civil liabilityA harmonised EU-wide cause of actionA matter for national law
PenaltiesMaximum penalty set no lower than 5% of net worldwide turnoverMaximum penalty capped at 3% of net worldwide turnover
TerminationTerminate as a last resortSuspend as a last resort
IdentificationMap impacts across the operationsScoping exercise, then in-depth assessment where most likely and severe
Supplier requestsNo Article 8(2a) limitNecessary information only; partners under 5,000 employees asked only where it cannot reasonably be obtained otherwise

The Stop-the-Clock Directive of April 2025 changed only dates, postponing first application by a year to July 2028.

Omnibus I then replaced the phased tiers with one set of thresholds and one date; recital 51 says the application dates “should be unified for all companies within the scope”.

The deletion of Article 22 is the most dangerous stale fact in the EU pack: a summary saying the duty was “softened to adopt” is wrong, because the final text deleted it.

Recital 47 gives the reason — the provisions were “deemed to be disproportionate” and could lead to legal uncertainty.

Transition planning has not disappeared entirely: companies in CSRD scope still disclose any climate transition plan they have under the ESRS, explained on our ESRS guide.

On liability, Article 29 now guarantees full compensation where national law holds a company liable, keeps a limitation period of at least five years and joint and several liability, and drops the representative-action and overriding-mandatory-provision rules.

The CSRD side of the same package is on CSRD after Omnibus I, and Dechert’s September 2026 briefing sets both side by side.

Enforcement

Supervisors, penalties and what is left of civil liability

Each Member State designates a supervisory authority with powers to investigate and impose penalties.

Omnibus I left that structure in place and cut the rest back.

Sources: consolidated Directive (EU) 2024/1760 Art 29 · Directive (EU) 2026/470 Art 4(20), recital 49
Article 29, as it now readsStatus after Omnibus I
29(1): a harmonised EU cause of action for damageDeleted — liability is a matter of national law
29(2): full compensation where a company is liable under national law, without punitive or multiple damagesKept, rewritten to point to national law
29(3)(a)–(c), (e): a limitation period of at least five years, non-prohibitive costs, injunctive relief, disclosure of evidenceKept
29(3)(d): standing for trade unions, NGOs and national human rights institutions to bring representative actionsDeleted
29(5): joint and several liability with subsidiaries and business partnersKept
29(7): the rule making the liability regime overriding, whatever law otherwise appliedDeleted

The consolidated text shows the deletions by absence: Article 29 runs straight from its heading to paragraph 2, paragraph 3 skips from (c) to (e), and the article ends at paragraph 6.

Recital 49 gives the reason: to better achieve subsidiarity, the Union-wide liability regime “should be removed”.

So the precise statement is that the CSDDD no longer creates EU-wide civil liability; whether a company can be sued for a due diligence failure, and on what basis, is each Member State’s law.

Pecuniary penalties are set nationally, but Article 27(4) now caps the maximum at 3% of net worldwide turnover — where the original text set 5% as the floor of the maximum.

Guidance is on its way: the Commission’s general due diligence guidelines are due by 26 July 2027, a delegated act on the content of the annual statement by 31 March 2029, and statements go to the European Single Access Point from 1 January 2031.

Comparison

CSDDD vs CSRD

The two directives are often read as one package because Omnibus I amended both.

They ask different things of different companies on different dates.

Sources: Dir (EU) 2024/1760 · Dir 2013/34/EU.
CSDDD: due diligenceCSRD: reporting
InstrumentDirective (EU) 2024/1760, as amendedDirective 2013/34/EU as amended by the CSRD and Omnibus I
EU company thresholdMore than 5,000 employees and €1.5bn worldwide turnoverMore than 1,000 employees and €450m net turnover
Non-EU thresholdMore than €1.5bn net turnover in the EUMore than €450m EU turnover in each of two years, plus a €200m subsidiary or branch
DutyFind, prevent, mitigate, suspend as a last resort, remediate, run a complaints procedureA sustainability statement under the ESRS, with limited assurance
Applies from26 July 2029Financial years beginning on or after 1 January 2027
Transposition26 July 202819 March 2027 for the Omnibus I changes
Transition plansNo duty (Article 22 deleted)Disclosure of any plan the company has
MaterialityRisk-based prioritisation of adverse impactsDouble materiality
Supplier request limitPartners with fewer than 5,000 employees (Art 8(2a))Protected undertakings with up to 1,000 employees (Art 19a(3))
EnforcementNational supervisors; penalties up to 3%; liability under national lawNational enforcement of the reporting duty

A company can be in CSRD scope and not CSDDD scope, but rarely the other way round.

For the reporting side, see double materiality and our guide to CSRD reporting for UK companies.

The European Commission’s CSDDD page tracks the guidelines as they are published.

Supplier requests

Which cap governs which question

The two caps sit in different directives, protect different suppliers and work in different ways.

The CSRD cap is in Article 19a(3) of Directive 2013/34/EU: a reporter may not require a “protected undertaking” — no more than an average of 1,000 employees in the preceding financial year — to provide more than the voluntary standard, and the supplier has a statutory right to decline the excess.

The CSDDD limit is in Article 8(2a) of Directive 2024/1760: for the in-depth assessment, a company may ask partners with fewer than 5,000 employees only for information that cannot reasonably be obtained by other means.

The first is a right the supplier invokes; the second is a condition on the customer, with no list of datapoints and no rule on contract terms.

The CSRD cap does not reach due diligence: its fifth subparagraph says nothing in it affects requests “for the purpose of complying with Union requirements on undertakings to conduct a due diligence process”.

A CSRD reporter may still ask for more than its cap, but must say which items exceed it and that the supplier may decline them, as the Commission’s explanation of the value chain cap puts it.

Enter your headcount and the stated purpose beside this text to see which rule governs.

Worked example: one supplier, two questionnaires

A UK precision components maker had 640 employees on average last year and sells to an EU machinery group with 7,200 employees and €3.1 billion turnover, in scope of both directives.

In the autumn of 2029 the customer sends two questionnaires.

Request A, for the customer’s CSRD statement, asks for Scope 1 and 2 emissions, energy, workforce figures and a full Scope 3 inventory.

The CSRD cap governs: the supplier answers the Annex II datapoints of the voluntary standard if it chooses, and may decline what the customer flags as beyond them, Scope 3 included.

Request B, for the customer’s CSDDD in-depth assessment, asks for sourcing countries of cobalt-bearing parts and the supplier’s own smelter audits.

Article 8(2a) governs: the customer may ask only if the information is necessary and cannot reasonably be had another way, for example from the smelter or public sources.

Change one number and the answer moves: at 1,400 employees request A is uncapped but request B is still limited; at 6,000 neither limit applies; and in 2027, request B is a commercial request because no Member State applies the CSDDD until 26 July 2029.

The mistake that costs suppliers most

Treating every EU questionnaire as a CSRD request and declining the over-cap parts.

A due diligence request sits outside the CSRD cap entirely.

Ask each customer, in writing, which duty a request serves.

Supplier requests · which cap governs?

What does the customer say the request is for?

Enter your headcount and say what the request is for.

Ask the customer in writing if the questionnaire does not say.

Rules: Directive 2013/34/EU Art 19a(3) as inserted by Directive (EU) 2026/470, and Art 5(1) of that Directive; Delegated Regulation (EU) 2026/1560 Arts 3–4; Directive (EU) 2024/1760 Arts 8(2a) and 37(1).

A provisional reading, not legal advice.

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Next steps

What a UK supplier should prepare now

Nothing in the CSDDD binds a UK supplier directly, and customer duties start in 2029.

The CSRD cap starts sooner, and customers are mapping their chains already.

1. Fix your headcount basis

Average employees over the preceding financial year, the CSRD test.

Note whether you are at or under 1,000, and under 5,000.

2. Write a self-declaration

A reporter may rely on a supplier’s self-declaration that it is protected, and need not verify it, unless it is manifestly incorrect.

3. Map your customers

Which EU customers are in CSRD scope (1,000 and €450m), and which in CSDDD scope (5,000 and €1.5bn, or €1.5bn of EU turnover).

4. Build the cap data pack

The Annex II datapoints of Delegated Regulation (EU) 2026/1560, which apply for financial years beginning on or after 1 January 2027.

5. Summarise your own risks

Sourcing countries, high-risk inputs and your own supplier checks, in the terms of the OECD Guidelines and the UN Guiding Principles.

6. Ask the purpose

Require each questionnaire to say whether it serves CSRD reporting or due diligence; the limits differ.

7. Check the contracts

Clauses that require over-cap CSRD data are not binding to that extent; due diligence clauses are unaffected.

8. Align the modern slavery statement

If total turnover is £36 million or more, the section 54 statement is already your public due diligence account.

Step 5 does the most work.

Article 8(2a) lets a customer ask only for information it cannot reasonably obtain by other means, so a supplier that publishes a clear risk summary reduces the questions it receives.

The voluntary standard, Delegated Regulation (EU) 2026/1560, was published on 21 September 2026 and entered into force on 24 September 2026; its Annex II is the list a protected supplier works from.

Our guide to VSME for UK suppliers sorts a typical questionnaire against it.

For step 8, turnover includes subsidiaries, and a statement that already describes risk assessment and supplier checks answers many of the questions an in-depth assessment asks.

Marsh’s note on supply-chain readiness is one practitioner’s checklist for the same preparation; the duties themselves are in the Directive.

By reader

What the CSDDD means for your organisation

The same directive lands differently depending on where a UK business sits in the chain.

A UK group with large EU sales

What applies. The UK parent is in scope if it generates more than €1.5 billion of net turnover in the EU, measured in the year before the last, in two consecutive years.

An EU subsidiary is in scope on its own figures above 5,000 employees and €1.5 billion worldwide turnover.

What to do. Test the parent on EU turnover and each EU subsidiary on the EU limb.

If in scope, plan an EU authorised representative, the scoping exercise and a complaints procedure.

When. Duties apply from 26 July 2029; annual statements for financial years starting on or after 1 January 2030.

A UK supplier to EU customers

What applies. Not in scope, but in the chain of activities of customers who are.

CSRD reporting requests are capped up to 1,000 employees; CSDDD requests are limited below 5,000.

What to do. Prepare a headcount self-declaration, a data pack built on the voluntary standard, and a short risk summary of your own supply chain.

Ask each customer which law a request serves.

When. The CSRD cap applies for financial years from 1 January 2027; CSDDD requests become statutory from 26 July 2029.

A UK group with a mid-sized EU subsidiary

What applies. Below 5,000 employees the subsidiary is outside the CSDDD, but it may be in CSRD scope above 1,000 employees and €450 million turnover, and it will be asked for due diligence data by in-scope customers.

What to do. Test the subsidiary under both directives separately — the thresholds and dates differ — and keep the two request limits apart in customer contracts.

When. CSRD for financial years from 1 January 2027; CSDDD customers from 26 July 2029.

Timeline

CSDDD key dates

Article 37(1) carries three dates, not one: national laws adopted and published by 26 July 2028, applied from 26 July 2029, and the annual statement under Article 16 for financial years starting on or after 1 January 2030.

Quoting one of the three as “the CSDDD deadline” is the error the provision invites.

The CSRD dates are included because the value-chain cap arrives more than two years before the CSDDD applies.

National laws are starting to appear.

Sweden’s inquiry proposes a new Corporate Responsibility Act in force on 26 July 2029, with minimum-level implementation and the National Board of Trade as supervisor, according to DLA Piper’s summary.

To test a harder group structure, put it to the member agent after creating a free account, or book a free 15-minute call.

  1. 25 Jul 2024
    Directive in force

    Directive (EU) 2024/1760.

  2. 18 Mar 2026
    Omnibus I in force

    Thresholds raised, one start date, Article 22 deleted.

  3. 24 Sep 2026
    Voluntary standard in force

    DR (EU) 2026/1560, the content of the CSRD cap.

  4. FY2027
    CSRD cap applies

    For financial years beginning on or after 1 January 2027.

  5. 19 Mar 2027
    CSRD transposition

    Omnibus I Articles 1 to 3.

  6. 26 Jul 2027
    Commission guidelines

    General due diligence guidelines due.

  7. 26 Jul 2028
    Transposition deadline

    National CSDDD laws adopted and published.

  8. 31 Mar 2029
    Statement content

    Delegated act on the annual statement due.

  9. 26 Jul 2029
    Application

    Due diligence duties apply to every in-scope company.

  10. 1 Jan 2030
    Annual statements

    For financial years starting on or after this date.

Terms

CSDDD terms, at the provision

Art 3(1)(g)

Chain of activities

Upstream business partners’ activities in producing the company’s goods or services, and downstream distribution, transport and storage carried out for the company.

Art 3(1)(f)

Business partner

A direct partner has a commercial agreement with the company; an indirect one performs business operations related to its operations, products or services.

Art 8(2)

Scoping exercise

The first step of identification, based solely on reasonably available information, to find where adverse impacts are most likely and most severe.

Art 8(2)

In-depth assessment

The second step, carried out only in the areas the scoping exercise flagged — the stage at which suppliers are asked for information.

Art 8(2a)

Information-request limit

Partners with fewer than 5,000 employees are asked only for information that cannot reasonably be obtained by other means.

Art 23

Authorised representative

A person established in the EU, mandated by a non-EU company in scope to act for it on its CSDDD obligations.

Frequently asked

Questions people ask

What is the CSDDD?

The Corporate Sustainability Due Diligence Directive, Directive (EU) 2024/1760, requires very large companies to identify, prevent, mitigate and bring to an end adverse human rights and environmental impacts in their own operations, their subsidiaries and their chains of activities.

It entered into force on 25 July 2024 and was amended by Directive (EU) 2025/794 and Omnibus I, Directive (EU) 2026/470.

Who is in scope of the CSDDD now?

After Omnibus I, an EU company is in scope if it had more than 5,000 employees on average and net worldwide turnover above €1.5 billion.

A non-EU company is in scope if it generated more than €1.5 billion of net turnover in the EU, measured in the financial year before the last.

A franchising and licensing limb catches EU royalties above €75 million with turnover above €275 million.

The conditions must be met in two consecutive financial years.

Does the CSDDD apply to UK companies?

A UK company is caught directly only if it generates more than €1.5 billion of net turnover in the EU in two consecutive years, or through an EU subsidiary that meets the EU thresholds itself.

Far more UK businesses will feel it as suppliers to in-scope EU customers.

There is no UK equivalent; the nearest UK duty is the modern slavery statement under section 54 of the Modern Slavery Act 2015.

Is the CSDDD mandatory or voluntary?

Mandatory for companies in scope, once their Member State has transposed it: national laws must be adopted by 26 July 2028 and applied from 26 July 2029.

For everyone outside scope it creates no duty, although in-scope customers will ask their suppliers for information.

When does the CSDDD apply?

From 26 July 2029, for every in-scope company at once.

The original phased dates of 2027, 2028 and 2029, and the 2028 date set by the 2025 postponement, no longer apply.

The annual statement applies for financial years starting on or after 1 January 2030.

Does the CSDDD still require a climate transition plan?

No. Omnibus I deleted Article 22, the duty to adopt and put into effect a climate transition plan, in its entirety.

Companies in CSRD scope still disclose any transition plan they have under the ESRS, but that is a reporting rule, not a due diligence duty.

What are the penalties under the CSDDD?

Member States set them, but the maximum pecuniary penalty is capped at 3% of net worldwide turnover.

The EU-wide civil liability regime was removed; whether a company can be sued for a due diligence failure is now a matter of national law, and the Directive guarantees full compensation where national law imposes liability.

What is the difference between the CSDDD and the CSRD?

The CSDDD is a due diligence law: find, prevent and address human rights and environmental harm, from 26 July 2029, for companies above 5,000 employees and €1.5 billion turnover.

The CSRD is a reporting law: a sustainability statement under the ESRS, from financial years beginning on or after 1 January 2027, for companies above 1,000 employees and €450 million.

Can a UK supplier refuse a CSDDD questionnaire?

Not in the way the CSRD allows.

The CSRD value-chain cap expressly does not affect due diligence requests.

Instead Article 8(2a) of the CSDDD limits the customer: it may ask business partners with fewer than 5,000 employees only for necessary information it cannot reasonably obtain by other means.

Until 26 July 2029 a request rests on the contract.

How is the CSDDD different from the UK Modern Slavery Act?

The Modern Slavery Act 2015 section 54 requires an organisation with total turnover of £36 million or more to publish an annual statement of the steps it has taken on slavery and human trafficking; it does not require any particular steps.

The CSDDD requires in-scope companies to carry out due diligence on a wide range of human rights and environmental impacts, with supervision and penalties.

Is there an EU-wide right to sue under the CSDDD?

No longer.

Omnibus I deleted the harmonised cause of action in Article 29(1).

Whether a company can be sued for a due diligence failure is a matter for each Member State’s law; where national law imposes liability, the Directive guarantees full compensation, a limitation period of at least five years and joint and several liability.

When will the Commission publish CSDDD guidance?

General due diligence guidelines are due by 26 July 2027.

A delegated act on the content of the annual statement is due by 31 March 2029, and statements are submitted to the European Single Access Point from 1 January 2031.

How do CSDDD requirements relate to climate transition plans and sustainability reporting?

Since Omnibus I, they do not overlap on transition plans: the CSDDD duty was deleted, and transition-plan disclosure lives in the CSRD and the ESRS.

On reporting, a company in scope of both publishes its due diligence information through the CSRD sustainability statement rather than a separate CSDDD statement.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner.

Secondary commentary is never the source for a number.

Checked against 11 sources fromEUR-LexEuropean CommissionEuropean Commission (DG FISMA)OECDOHCHRlegislation.gov.uk
  1. EUR-Lex
    Directive (EU) 2024/1760 (CSDDD), consolidated 18.03.2026 — Arts 1, 2, 3, 8, 27, 29, 37

    Scope, the two-stage identification duty, the Art 8(2a) request limit, penalties, liability and dates.

  2. EUR-Lex
    Directive (EU) 2026/470 (Omnibus I), Art 4 and recitals 37, 39, 47, 49, 51

    The thresholds raised, Article 22 deleted, civil liability moved to national law, one application date.

  3. EUR-Lex
    Directive 2013/34/EU, consolidated 18.03.2026 — Art 19a(3) and 29a(3)

    The CSRD value-chain cap and its express due-diligence carve-out.

  4. EUR-Lex
    Delegated Regulation (EU) 2026/1560 — standard for voluntary use, Annex II

    The datapoints that make up the CSRD value-chain cap.

  5. European Commission
    Corporate sustainability due diligence

    The Commission’s page, tracking the guidelines as they are published.

  6. European Commission (DG FISMA)
    Additional explanatory information regarding the value chain cap, 6 May 2026

    The CSRD cap applies only to CSRD reporting requests.

  7. OECD
    OECD Guidelines for Multinational Enterprises on Responsible Business Conduct

    The international standard the Directive builds on.

  8. OHCHR
    UN Guiding Principles on Business and Human Rights

    The UN framework the Directive builds on.

  9. legislation.gov.uk
    Modern Slavery Act 2015, section 54

    The UK’s nearest supply-chain duty: an annual statement.

  10. legislation.gov.uk
    SI 2015/1833, regulation 2

    The £36 million total turnover threshold for the section 54 statement.

  11. Home Office (GOV.UK)
    Transparency in supply chains: a practical guide

    Statutory guidance on the modern slavery statement.

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