Use the binding rules after Directive (EU) 2026/470. Older guides built around the EUR 450 million and 1,000-employee general route, lower franchise thresholds, or staggered 2027-2029 waves no longer describe current CSDDD scope.
This is an entity-and-group legal test. Supplier risk, customer requests, or voluntary OECD alignment can justify due diligence work without placing the company itself in CSDDD scope.
Start with where the company is formed, then test , employee count where applicable, ultimate-parent treatment, exclusions, and the two-consecutive-financial-years rule. Companies that remain in scope apply national measures from 26 July 2029.
For a company formed under Member State law, the amended main route requires more than 5,000 employees on average and more than EUR 1.5 billion net worldwide turnover in the last financial year for which annual financial statements have been or should have been adopted. An ultimate parent can be tested on consolidated group figures under the parent-company route.
Both thresholds must be exceeded for each of two consecutive financial years. Scope ends only after the relevant conditions cease to be met for each of the last two relevant financial years. Do not reuse the original Directive's lower 1,000-employee and EUR 450 million test.
Calculate part-time employees on a full-time-equivalent basis. Include temporary agency workers and other non-standard workers when they meet the Court of Justice worker-status criteria, count seasonal workers in proportion to months employed, and include employees and turnover of legally dependent branches. Keep the calculation method with the conclusion.
Directive (EU) 2026/470 raised, rather than removed, the distinct franchise and licensing thresholds. The Directive does not apply to alternative investment funds (AIFs) or undertakings for collective investment in transferable securities (UCITS); a fund manager or another regulated financial undertaking can still fall within the Directive's company definition and requires its own test.
Sources (2)
Binding amendment supporting the current Article 2 scope and parent-company rules.
Current source for employee calculation, the two-year entry and exit rule, AIF and UCITS exclusions, and the holding-company exemption process and liability.
A company formed outside the EU is tested by generated in the Union, not by an EU employee threshold. The general threshold is more than EUR 1.5 billion net Union turnover in the financial year preceding the last financial year, including the relevant consolidated ultimate-parent analysis.
The threshold must be met for two consecutive financial years, and scope ends only after it has ceased to be met for each of the last two relevant financial years. Keep the turnover methodology and Member State allocation reviewable.
An in-scope third-country company must designate an established or domiciled in a Member State where it operates. The appointment becomes valid when the representative accepts it, and the company must give the representative the powers and resources needed to receive communications and cooperate with supervisory authorities.
Sources (2)
Binding source for the amended third-country threshold and related scope provisions.
Current source for the two-year rule, authorised representative, and third-country supervisory-authority provisions.
Member States must transpose the amended Directive by 26 July 2028. National measures apply from 26 July 2029 to all companies that remain in Article 2 scope; there is no longer a separate 2028 first wave under the superseded 2025 schedule.
A company below Article 2 thresholds may still receive necessary, targeted information or contract requests from an in-scope business partner. That indirect commercial effect is not the same as direct CSDDD scope. During an Article 8 in-depth assessment, an in-scope company may request information from a partner with fewer than 5,000 employees only when it cannot reasonably obtain the information by other means.
Sources (2)
Current source for 2028 transposition, 2029 application, and the amended scope framework.
Original framework; use with the 2026 amendment rather than as a standalone statement of current law.
Keep entity, group, employee, turnover, exclusion, authorised-representative, timing, and reassessment evidence in one reviewed file.
Connect the CSDDD decision to cited sources, owners, evidence, and reviewable implementation work.
Return to current scope, dates, due diligence, reporting, and enforcement guidance.
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Test third-country CSDDD scope using the amended EUR 1.5 billion EU-turnover route and one 26 July 2029 application date.
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Directive (EU) 2026/470 removed the standalone CSDDD Article 22 climate-transition-plan duty. Understand what changed and which separate obligations may remain.
FAQ on how the CSDDD defines chain of activities boundaries for subsidiaries, direct and indirect business partners, upstream activities, downstream logistics, and evidence.
FAQ on Article 14 CSDDD complaint and notification mechanisms, who may complain, follow-up rights, confidentiality, retaliation, and evidence.
How CSDDD Articles 10 and 11 use contractual assurances with business partners, verification, SME support, action plans, and possible suspension escalation.
CSDDD FAQ on when to prevent or mitigate potential adverse impacts, when to end or minimise actual adverse impacts, and what evidence records to keep.
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How to prioritise CSDDD adverse impacts when teams cannot address everything at once, using severity, likelihood, stakeholder evidence, and a reviewable rationale.
No separate company scope waves remain after Directive (EU) 2026/470: transposition is due in 2028 and all companies remaining in scope apply from 2029.
Directive (EU) 2026/470 retained the CSDDD franchise and licensing scope route but raised its royalty and turnover thresholds. Learn the current test.
FAQ on how OECD responsible business conduct guidance, the UN Guiding Principles, and ILO labour standards inform CSDDD due diligence without being the same legal instrument.
Directive (EU) 2026/470 removed the uniform EU liability test but retained compensation and procedural safeguards. Claims still depend on Member State law.
Directive (EU) 2026/470 removed the standalone CSDDD Article 22 climate-transition-plan duty; separate CSRD and national obligations need their own review.
CSDDD Omnibus amendment: what Directives (EU) 2025/794 and 2026/470 adopted, which dates apply, and which old duties were removed.
A third-country company generally needs more than EUR 1.5 billion net turnover in the EU under Directive (EU) 2026/470; learn the evidence and timing.