EU CSDDD (Directive (EU) 2024/1760) Implementation checklist

Confirm whether the relevant entity or group is in scope, document the application wave, and assign accountable owners across legal, procurement, ESG, compliance, and risk functions.

If a parent performs duties on behalf of subsidiaries, write down how that works, what data subsidiaries must provide, and which subsidiary remains exposed to local supervision and civil liability risk.

Create the due diligence policy, code of conduct, mapping methodology, and prioritization method before you ask suppliers for more data. These articles set the logic that later actions must follow.

The prioritization model should record severity and likelihood, and should explain how company, geographic, sector, product, and purchasing-practice risk factors are assessed.

For potential impacts, maintain prevention action plans, contractual assurances, verification methods, and escalation routes. For actual impacts, maintain corrective action plans and clear criteria for when suspension or termination is considered.

Where the company caused or jointly caused an actual adverse impact, make sure remediation workflows can restore or compensate affected persons, communities, or the environment proportionately to the company implication.

Set up stakeholder engagement points across mapping, prioritization, action planning, remediation, and monitoring. Complaints need to be fair, publicly available, accessible, predictable, and transparent.

Monitoring must happen at least every 12 months and after significant change. Keep the indicators, reviews, and management decisions in one place.

If the annual statement under Article 16 applies, set up data collection, approval, publication, and later ESAP submission processes. If CSRD reporting already covers the company, confirm the annual statement exemption but still keep the underlying due diligence evidence.

For Article 22, adopt and put into effect a transition plan with 2030 and five-year targets to 2050, investment assumptions, key actions, and governance roles. Also prepare for supervisory requests, substantiated concerns, penalties, and civil liability disputes.