The original Article 22 required covered companies to adopt and put into effect a climate-change mitigation transition plan. Directive (EU) 2026/470 removed that CSDDD obligation.
Removal from CSDDD does not establish that the company has no climate reporting, transition-plan, national-law, contractual, or voluntary commitments under another framework.
Directive (EU) 2026/470 deleted with effect from 18 March 2026, before the CSDDD duties are due to apply to companies. Do not maintain the former Article 22 plan as a current CSDDD obligation. Record the legal change, then test current CSRD rules, national climate law, sector rules, financing terms, contracts, and public commitments separately.
Directive (EU) 2024/1760 originally required covered companies to adopt and put into effect, through best efforts, a climate-change mitigation transition plan. The plan was to include time-bound targets, decarbonisation levers and actions, supporting investment and funding, and the role of administrative, management, and supervisory bodies. It also had to be updated every 12 months with a progress description. Directive (EU) 2026/470 deleted Article 22 in full.
The broader Omnibus proposal is legislative history. The adopted 2026 Directive is the binding amendment, and Article 22 is no longer part of the CSDDD. Because Member States apply the amended CSDDD measures from 26 July 2029, no company reaches a CSDDD application date at which the former Article 22 duty survives.
Sources (2)
Binding amendment published on 26 February 2026, effective on 18 March 2026, whose Article 4(16) deletes CSDDD Article 22.
Historical source for the former best-efforts duty, plan content, governance description, and 12-month update; it must be read with the 2026 amendment.
Other climate obligations and commitments can remain after Article 22's deletion. The legal, sustainability-reporting, finance, risk, and business owners should test each basis before deleting the plan or its controls. A CSRD disclosure duty, for example, is different from the former CSDDD duty to adopt and put a plan into effect, and its scope must be checked under the amended Accounting Directive and the applicable national transposition.
Sources (1)
Also amends the CSRD framework; current CSRD scope and disclosures must be assessed under the amended and nationally transposed rules rather than the original 2022 act alone.
Use a control-by-control change record rather than deleting the plan as one object. For each target, action, investment line, governance responsibility, disclosure, or assurance procedure, name the owner, former Article 22 basis, any surviving basis, decision, approver, evidence location, and next review trigger.
Sources (2)
Current CSDDD amendment supporting the obligation-status change.
Current consolidated text showing that Article 22 has been deleted while the human-rights and environmental due diligence provisions remain.
Map each plan control to its current legal or voluntary basis before retiring, relabelling, or reusing it.
Connect the CSDDD decision to cited sources, owners, evidence, and reviewable implementation work.
Return to current scope, dates, due diligence, reporting, and enforcement guidance.
Review the relevant entity, national-law dependency, evidence gap, and next control decision with Sorena.
A CSDDD workflow for identifying actual and potential adverse human rights and environmental impacts, ranking severity and likelihood, and documenting prevention, mitigation, remediation, and stakeholder evidence.
Test CSDDD scope after Directive (EU) 2026/470 using the current EU and third-country thresholds, parent-company rules, exclusions, dates, and evidence.
Explain CSDDD chain-of-activities scope, upstream and downstream boundaries, subsidiaries, direct and indirect business partners, supplier risk segmentation, and evidence.
Define CSDDD upstream and downstream chain of activities boundaries for subsidiaries, direct and indirect business partners, distribution, transport, storage, and records.
A source-backed CSDDD compliance guide covering due diligence policy, impact scoping, prevention, corrective action, complaints, monitoring, reporting, climate-plan status, and supervisory evidence.
Current CSDDD calendar: 2027-2028 guidance, 2028 transposition, 2029 application, 2030 reporting, 2031 ESAP submission and review.
A source-backed CSDDD checklist for scope, risk scoping, impact prioritisation, action plans, complaints, monitoring, communication, evidence, and the removed climate-plan duty.
A playbook using current CSDDD provisions for policy integration, impact assessment, prioritisation, prevention, correction, remediation, stakeholder engagement, complaints, monitoring, communication, and evidence.
Practical answers on CSDDD scope, current application dates, chain of activities, due diligence duties, complaints, remediation, civil liability, climate plans, and evidence.
Build a CSDDD grievance, notification, stakeholder engagement, and remediation workflow under Directive (EU) 2024/1760 as amended by Directive (EU) 2026/470.
Understand CSDDD supervision, national penalties, substantiated concerns, remedial orders, and civil-liability analysis after Directive (EU) 2026/470.
Test third-country CSDDD scope using the amended EUR 1.5 billion EU-turnover route and one 26 July 2029 application date.
Current CSDDD penalty guidance after the EU 5% rule was replaced by a uniform 3% maximum limit: national sanctions, authority decisions, evidence, and country-by-country monitoring.
A CSDDD remediation plan template for actual adverse impacts, complaint inputs, stakeholder engagement, action records, and monitoring under the Directive as amended in 2026.
A source-backed map of current CSDDD requirements across scope, due diligence policy, impact assessment, complaints, remediation, monitoring, communication, and the removed climate-plan duty.
Understand amended CSDDD thresholds for EU and non-EU companies, group scope, exclusions, two-year evidence, and the 2029 application date.
Review supplier contract clauses against CSDDD Articles 10 and 11: contractual assurances, verification, SME fairness, support, action plans, and escalation evidence.
How to use CSDDD supplier contract clauses without treating clauses as a substitute for due diligence: contractual assurances, verification, SME support, action plans, limits, and evidence.
A CSDDD supplier impact scoring template for Article 8 identification, Article 9 prioritisation, severity, likelihood, stakeholder input, chain-of-activities boundaries, and evidence records.
Compare CSDDD due diligence duties with CSRD sustainability reporting, including scope, timing, Article 16 reporting, evidence overlap, assurance, and enforcement.
Compare the EU CSDDD with Germany's LkSG without mixing directive duties, national-law duties, chain boundaries, complaints, reporting, and enforcement routes.
Compare the binding EU CSDDD with the OECD Guidelines for responsible business conduct across scope, due diligence duties, business relationships, remediation, and evidence.
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.
FAQ on CSDDD remediation: when Article 12 requires remedy, how complaints and stakeholder engagement affect the response, and what evidence to keep.
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.