CSDDD After the Omnibus: What Still Applies and What Companies Must Do

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After months of uncertainty, the Omnibus amendments to the Corporate Sustainability Due Diligence Directive (CSDDD) have brought clarity. While the scope has narrowed and some requirements were adjusted, the directive’s core purpose remains unchanged: companies are still expected to identify, prevent, and address human rights and environmental risks across their operations and value chains.

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What is the CSDDD?

The Corporate Sustainability Due Diligence Directive requires companies to take responsibility for how their business activities affect people and the environment.

At its core, CSDDD expects companies to:

  • Identify human rights and environmental risks
  • Prevent and mitigate harm
  • Address actual impacts
  • Apply due diligence across operations, subsidiaries, and value chains

This is not a one-time exercise. It is about embedding due diligence into how a business operates over time.

Who remains in scope

Following the Omnibus changes, the scope has been reduced but remains significant.

CSDDD applies to:

  • EU companies with more than 5,000 employees and €1.5 billion in global turnover
  • Non-EU companies with €1.5 billion in EU turnover
  • Certain franchising and licensing models meeting specific thresholds

A review clause allows for potential future expansion of the scope.

What changed under the Omnibus

The Omnibus amendments adjusted how companies are expected to comply, aiming to reduce complexity and administrative burden.

Key changes include:

  • Removal of the climate transition plan requirement
  • Termination of business relationships no longer mandatory
  • Narrower definition of stakeholders
  • Fewer information requests to smaller business partners
  • Monitoring required at least every five years (instead of annually)
  • Penalties capped at 3% of global net turnover
  • Civil liability left to national law

These changes simplify implementation, but they do not remove responsibility.

What still applies

Despite the adjustments, the core due diligence obligations remain.

Companies in scope are still required to:

  • Conduct risk-based due diligence across the value chain
  • Integrate due diligence into policies and risk management systems
  • Engage stakeholders in a meaningful way
  • Establish grievance and remediation mechanisms
  • Monitor the effectiveness of due diligence measures
  • Communicate publicly on due diligence efforts

In practice, this means companies must still understand where risks exist, listen to affected stakeholders, and act when harm is identified.

Timeline toward compliance

The Omnibus changes also clarified the timeline.

  • Transposition into national law: by July 2028
  • Compliance required: from July 2029

While this provides additional time, building effective due diligence systems — especially across complex supply chains — takes longer than many expect.

Why this matters

CSDDD is not only about legal compliance. It reflects a broader shift in expectations around how companies manage risk, responsibility, and resilience.

Policies alone will not be enough. Regulators, investors, and stakeholders are increasingly focused on whether due diligence works in practice — and whether people across the organization understand what is expected of them.

Making due diligence work in practice

Get in touch to learn how Quizrr helps companies prepare for CSDDD compliance.

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