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CSDDDChanged in 2026

The standalone CSDDD climate-plan duty was removed

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.

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Author
Sorena AI
Published
Feb 21, 2026
Updated
Jul 31, 2026
Sections
3

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Jul 31, 2026
Overview

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.

Section 1

What changed legally

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.

  • Archive the old Article 22 citation as superseded legal history.
  • Remove claims that CSDDD itself still requires the former best-efforts implementation duty, specified plan content, or 12-month update.
  • Update policies, obligation registers, training, assurance scopes, and public summaries that still call Article 22 current law.
Sources for this answer
Directive (EU) 2026/470
Binding amendment published on 26 February 2026, effective on 18 March 2026, whose Article 4(16) deletes CSDDD Article 22.
Original Directive (EU) 2024/1760
Historical source for the former best-efforts duty, plan content, governance description, and 12-month update; it must be read with the 2026 amendment.
Section 2

What teams should check before retiring climate work

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.

  • Current CSRD and transposed national sustainability-reporting requirements applicable to the undertaking or group, including any transition-plan disclosures that remain in scope.
  • Sector, prudential, listing, procurement, financing, grant, or contractual commitments.
  • Published targets, transition claims, investor communications, and consumer-law substantiation risk.
  • Operational climate risks that still qualify as environmental adverse impacts in the due diligence system.
  • Separate national climate or due-diligence laws. Do not describe them as a surviving EU-level duty.
Sources for this answer
Directive (EU) 2026/470
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.
Section 3

Evidence the status decision

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.

  • Record the former obligation, Article 4(16) of the amending Directive, the 18 March 2026 effective date, and every affected control.
  • Map every climate-plan control to its remaining legal, contractual, risk-management, or voluntary basis.
  • Retire only controls with no remaining legal, contractual, risk-management, or voluntary basis. Relabel reused controls so they are not presented as CSDDD-mandated.
  • Keep a change log for public claims, board materials, assurance plans, and supplier requests.
Sources for this answer
Directive (EU) 2026/470
Current CSDDD amendment supporting the obligation-status change.
Consolidated Directive (EU) 2024/1760 as at 18 March 2026
Current consolidated text showing that Article 22 has been deleted while the human-rights and environmental due diligence provisions remain.

Reconcile the removed CSDDD duty with remaining climate obligations

Map each plan control to its current legal or voluntary basis before retiring, relabelling, or reusing it.

Research workflow
Open Research Copilot

Connect the CSDDD decision to cited sources, owners, evidence, and reviewable implementation work.

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Next step
Open the amended CSDDD hub

Return to current scope, dates, due diligence, reporting, and enforcement guidance.

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Talk to Sorena
Discuss CSDDD implementation

Review the relevant entity, national-law dependency, evidence gap, and next control decision with Sorena.

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Primary sources

References and citations

Directive (EU) 2026/470
eur-lex.europa.eu
Referenced sections
  • Current CSDDD amendment supporting the obligation-status change.
Original Directive (EU) 2024/1760
eur-lex.europa.eu
Referenced sections
  • Historical source for the former best-efforts duty, plan content, governance description, and 12-month update; it must be read with the 2026 amendment.
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