CSDDDCSRDEU

CSDDD vs CSRD due diligence and reporting compared

CSDDD is an operational due diligence regime for human rights and environmental adverse impacts. is a sustainability reporting regime built around management-report disclosure and standards.

This comparison helps keep duties, evidence, reporting, timing, and enforcement separate while reusing data where the same facts genuinely support both regimes.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

CSDDD and both sit in the EU sustainability framework, but they answer different compliance questions. CSDDD asks whether a covered company has identified, prevented, mitigated, ended, remediated, monitored, and communicated about adverse impacts in its own operations, subsidiaries, and chain of activities. CSRD asks whether an in-scope undertaking reports sustainability information under the Accounting Directive as amended by Directive (EU) 2022/2464 and the European Sustainability Reporting Standards.

Comparison matrix

CSDDD vs CSRD: what changes in practice

Read the rows as a separation tool: one workstream designs and operates due diligence controls, while the other prepares reportable sustainability information. Some source data can overlap, but the legal trigger and output are not the same.

Review all sources
First framework
CSDDD

Operational human rights and environmental due diligence for covered companies, including policies, impact mapping, prevention, mitigation, remediation, stakeholder engagement, complaints, monitoring, and public communication. Directive (EU) 2026/470 removed the standalone CSDDD climate-plan duty.

Second framework
CSRD

Corporate sustainability reporting under Directive (EU) 2022/2464 and delegated acts, focused on publishing sustainability information for investors and other stakeholders through the reporting framework.

Scope boundary

CSDDD

After Directive (EU) 2026/470, CSDDD scope generally requires an EU company to exceed 5,000 employees and EUR 1.5 billion net worldwide turnover, or a third-country company to exceed EUR 1.5 billion net turnover in the Union. Relevant ultimate-parent routes remain, along with a separate franchise and licensing route above EUR 75 million in qualifying Union royalties and EUR 275 million turnover.

CSRD

After Directive (EU) 2026/470, the main EU scope test requires an undertaking to exceed both EUR 450 million net turnover and an average of 1,000 employees during the financial year. The same thresholds apply on a consolidated basis to parent undertakings of groups. The directive also changes the issuer and third-country undertaking routes, so those cases need their own Accounting Directive and national-law analysis.

Operational implication

A company can be in before, after, or without being in CSDDD. Run separate scoping checks and keep the assumptions visible: employee count, turnover, public-interest or listing status, parent-group status, EU branch or subsidiary facts, and any non-EU turnover facts.

Operational due diligence and reporting

CSDDD

CSDDD creates duties to conduct risk-based human rights and environmental due diligence. The core work is operational: integrate due diligence into policies, identify and assess adverse impacts, prioritise, prevent or mitigate potential impacts, end or minimise actual impacts, remediate, engage stakeholders, run complaints and notification channels, monitor effectiveness, and communicate.

CSRD

modernises corporate sustainability reporting. The reporting work is to collect, verify, and publish sustainability information under Directive (EU) 2022/2464 and standards adopted for Directive 2013/34/EU.

Operational implication

Do not treat a report as proof that CSDDD due diligence has been performed. A report may describe due diligence, but CSDDD requires the underlying due diligence process and measures.

Supply-chain and reporting boundaries

CSDDD

CSDDD uses the defined 'chain of activities': upstream business-partner activities linked to production or services, and certain downstream distribution, transport, and storage activities carried out for or on behalf of the company. It is not a generic entire-value-chain disclosure label.

CSRD

reporting boundaries and disclosures are governed by the sustainability reporting framework and . Reporting evidence may include value-chain information, but that does not automatically match CSDDD's chain-of-activities definition.

Operational implication

Reuse supplier or site data only after checking that the same legal entity, operation, business partner, activity, geography, and impact are relevant to both the CSDDD chain-of-activities analysis and the disclosure.

Public reporting requirements

CSDDD

CSDDD Article 16 requires companies to publish an annual statement on matters covered by the directive unless an exemption applies. It expressly says Article 16(1) does not apply to companies subject to sustainability reporting requirements under Articles 19a, 29a, or 40a of Directive 2013/34/EU, including specified exemptions.

CSRD

is the reporting framework that amended Directive 2013/34/EU and empowered delegated and implementing acts. provides the sustainability reporting standards adopted under that framework.

Operational implication

For companies already subject to sustainability reporting, Article 16 is a coordination point, not a duplicate annual-statement workstream. Still keep the amended CSDDD due diligence evidence. Directive (EU) 2026/470 removed the standalone CSDDD Article 22 duty, but separate CSRD transition-plan disclosure analysis may remain.

Evidence record

CSDDD

CSDDD evidence should prove the operating process: due diligence policy, impact mapping, severity and likelihood prioritisation, prevention and corrective action plans, contractual assurances and verification, SME support decisions, stakeholder engagement, complaints, remediation, monitoring, and updates after significant change.

CSRD

evidence should prove reportable sustainability information: data sources, materiality judgements, disclosures, controls over the sustainability statement, and alignment with the applicable requirements.

Operational implication

One dataset can feed both regimes, but the evidence pack needs two mappings: 'what did we do to identify and address impacts?' for CSDDD, and 'what did we disclose and why is it reportable?' for .

Timing and deadlines

CSDDD

CSDDD timing now reflects Directive (EU) 2026/470. Member States transpose by 26 July 2028, all companies remaining in amended scope apply from 26 July 2029, and Article 16 measures apply for financial years starting on or after 1 January 2030.

CSRD

Directive (EU) 2026/470 replaces the old wave structure for future reporting. Undertakings in the amended second-wave scope report for financial years starting on or after 1 January 2027. First-wave undertakings remain subject for financial years starting in 2024, 2025, and 2026, but Member States may exempt undertakings below the new EUR 450 million or 1,000-employee thresholds for financial years beginning in 2025 and 2026. Listed SMEs are removed from the mandatory regime.

Operational implication

Use separate date registers and check national implementation of the optional 2025-2026 exemption. CSDDD readiness runs to 26 July 2029; reporting depends on the amended financial-year rules, the entity's category, and the national law that implements the directive.

Enforcement

CSDDD

CSDDD enforcement remains a Member State supervisory and national-law track. Directive (EU) 2026/470 replaced the original EU 5% rule with a uniform 3% maximum limit and changed the harmonised civil-liability provisions, so imposed penalty amounts and private claims still require country-specific transposition and private-law analysis.

CSRD

duties operate through the Accounting Directive and national transposition. Article 34 governs assurance of sustainability reporting, including investigation and sanction systems for assurance providers, while Article 51 requires Member States to provide effective, proportionate, and dissuasive penalties for infringements of national provisions adopted under the Directive. These reporting provisions do not create the CSDDD route for damage caused by due diligence failures.

Operational implication

Do not copy penalty or liability statements between regimes. CSDDD exposure follows due diligence failures and national transposition; exposure follows sustainability reporting duties and assurance/reporting controls.

Which framework applies

CSDDD

Use CSDDD when the question is: what must the company do about actual or potential human rights or environmental adverse impacts in its operations, subsidiaries, and chain of activities?

CSRD

Use when the question is: what sustainability information must the undertaking report, under which standard, for which financial year, and with what reporting controls?

Operational implication

Build one shared fact base, then maintain two outputs: an operating due diligence file for CSDDD and a reporting file for . Reuse only facts, not legal conclusions.

Climate-transition-plan treatment

CSDDD

Directive (EU) 2026/470 removed the standalone CSDDD Article 22 climate-transition-plan duty. A company may still face transition-plan disclosures or other climate obligations, but those are not current CSDDD requirements merely because the original 2024 text contained Article 22.

CSRD

/ can be the place where the transition plan is reported. That reporting link does not turn every ESRS climate disclosure into a CSDDD due diligence measure.

Operational implication

Do not maintain a CSDDD transition-plan workstream after Article 22's deletion. If or another source still requires climate disclosure or planning, label that evidence under the source that actually applies.

Practical decision rule

How should teams decide between CSDDD and CSRD?

  • If the work changes supplier engagement, impact assessment, prevention, mitigation, remediation, complaints, or monitoring, treat it as a CSDDD due diligence workstream.
  • If the work changes the sustainability statement, datapoints, materiality documentation, assurance file, or management-report publication, treat it as a reporting workstream.
  • If the same evidence supports both, record the specific fact being reused and keep the CSDDD legal conclusion separate from the disclosure conclusion.
Section 1

Where the two regimes overlap

The strongest overlap is evidence, not obligation. Supplier maps, incident logs, grievance records, human-rights risk assessments, environmental impact assessments, site data, purchasing-practice changes, remediation decisions, and transition-plan materials may be useful for both regimes.

The weak point is overclaiming. CSDDD evidence should show how the company identified and addressed actual or potential adverse impacts. evidence should show why the disclosed sustainability information is complete, supportable, and aligned to the reporting standard.

  • Keep a shared source register for factual records such as entity data, supplier data, impact assessments, and climate-plan documents.
  • Keep separate legal mappings for amended CSDDD Articles 7-16 and for / disclosure requirements; record the former Article 22 only as superseded history.
  • Do not describe an disclosure as a CSDDD control unless the CSDDD source requirement and the underlying operating action are both documented.
Recommended next step

Separate CSDDD due diligence from CSRD reporting

Use the comparison to build one fact base with two controlled outputs: a CSDDD due diligence file and a CSRD reporting file.

Section 2

What to review before publishing a comparison or roadmap

Before publishing a CSDDD and roadmap, verify whether each date comes from original law, national transposition, a Commission proposal, or an adopted amendment. Directive (EU) 2026/470 is in force and replaces proposal-stage and 2025-only timing summaries. For CSRD, also check whether the relevant Member State used the optional exemption for financial years beginning in 2025 and 2026.

Also separate the Article 16 communication question from the broader due diligence question. A company subject to sustainability reporting may not need a duplicate CSDDD annual statement under Article 16, but it still needs evidence for the CSDDD duties that apply to it.

  • Mark each date as original law, historical proposal, Directive (EU) 2025/794 timing history, adopted Directive (EU) 2026/470, or national transposition, and record whether the optional exemption was implemented.
  • Confirm whether the company is subject to Articles 19a, 29a, or 40a of Directive 2013/34/EU before relying on the CSDDD Article 16 exemption.
  • Use the same source record for both workstreams only when the same fact, reporting period, entity boundary, and impact boundary match.
Primary sources

References and citations

eur-lex.europa.eu17 citations
Referenced sections
  • Primary CSDDD source for scope, due diligence duties, chain-of-activities definition, Article 16 communication, transition plans, timing, supervision, penalties, and civil liability.
  • Articles 7-16 and 22 ground the operating evidence needed for CSDDD.
  • Original Articles 16 and 37 source; use Directive (EU) 2026/470 for the current communication and timing analysis.
Show 14 more
  • CSDDD Article 2 uses its own scope tests rather than CSRD reporting status.
  • Article 5 lists the CSDDD due diligence actions that distinguish the regime from reporting-only obligations.
  • Article 5 supports the distinction between operating due diligence and merely publishing information about it.
  • Article 3 defines chain of activities for CSDDD.
  • CSDDD scope of business-partner activities should be checked before reusing CSRD value-chain evidence.
  • Article 16 sets the annual statement rule and exemption for companies subject to specified Accounting Directive sustainability reporting provisions.
  • Article 16(3) instructs the Commission to align CSDDD reporting criteria with sustainability reporting standards as appropriate.
  • Articles 7-15 support the listed CSDDD operating evidence categories.
  • CSDDD Article 8 permits use of appropriate resources and information gathered through complaints and notification mechanisms.
  • CSDDD Article 29 civil liability is tied to specified due diligence failures and damage.
  • Article 1 and Article 5 frame CSDDD as obligations relating to adverse impacts and due diligence actions.
  • Historical source for the former Article 22 duty, removed by Directive (EU) 2026/470.
  • Historical source for the former Article 22 twelve-month update rule; it does not preserve that duty after the 2026 deletion.
  • Original CSDDD source, read with Directive (EU) 2026/470 for current duties, Article 16, timing, supervision, penalties, civil liability, and removal of Article 22.
"risk-based human rights and environmental due diligence"
More quoted passages
"identify and assess actual and potential adverse impacts"
"no later than 12 months"
"This Directive shall apply to companies"
"companies conduct risk-based human rights and environmental due diligence"
"publicly communicating on due diligence"
"activities of a company's upstream business partners"
"where related to their chains of activities"
"Paragraph 1 of this Article shall not apply"
"align them as appropriate"
"monitor the adequacy and effectiveness"
"quantitative and qualitative information"
"damage caused to a natural or legal person"
"actual and potential human rights adverse impacts"
"adopt and put into effect a transition plan"
"updated every 12 months"
eur-lex.europa.eu10 citations
Referenced sections
  • Binding current amendment for CSDDD and CSRD scope, timing, reporting, enforcement, civil liability, and transition-plan status.
  • Binding source for the current CSDDD and CSRD scope and timing rules, including the optional CSRD exemption for financial years beginning in 2025 and 2026.
  • Article 4(2) amends CSDDD Article 2 with the current employee, turnover, franchise, and licensing scope tests.
Show 7 more
  • Articles 2 and 4 amend the Accounting Directive and CSRD scope, including the EUR 450 million turnover and 1,000-employee tests and the revised issuer and third-country routes.
  • Uses separate Accounting Directive reporting tests and CSDDD company-scope tests, confirming that one regime's coverage does not establish the other's.
  • Article 4(22) replaces CSDDD Article 37 with the 26 July 2028 transposition deadline, 26 July 2029 application date, and 1 January 2030 Article 16 financial-year rule.
  • Articles 2 and 4 establish the amended CSRD scope, financial-year sequence, optional 2025-2026 exemption, and removal of listed SMEs from mandatory reporting.
  • The adopted amendment gives the two frameworks different application mechanics, supporting separate date and scope records.
  • Article 4(17) to 4(20) provides the current supervisory, 3% maximum-penalty, and national-law civil-liability rules.
  • Article 4(16) deletes CSDDD Article 22 and is the current legal basis for ending the CSDDD transition-plan workstream.
eur-lex.europa.eu8 citations
Referenced sections
  • ESRS delegated regulation source used to distinguish CSRD sustainability reporting evidence from CSDDD due diligence evidence.
  • ESRS delegated act grounds the CSRD reporting-standard evidence side.
  • Delegated regulation supplementing Directive 2013/34/EU with European Sustainability Reporting Standards.
Show 5 more
  • ESRS source for the reporting-standard side of the comparison.
  • Source for the ESRS reporting standards referenced by the comparison.
  • ESRS delegated act supports treating CSRD evidence as disclosure and reporting-standard evidence.
  • ESRS delegated act supports the reporting side of climate-transition-plan evidence.
  • Primary source for the first set of European Sustainability Reporting Standards under the CSRD reporting framework.
"sustainability reporting standards"
More quoted passages
"as regards sustainability reporting standards"
"supplementing Directive 2013/34/EU"
finance.ec.europa.eu7 citations
Referenced sections
  • Official Commission source for Directive 2022/2464 and CSRD delegated and implementing acts.
  • Official Commission page identifying Directive 2022/2464 as the corporate sustainability reporting directive and linking the ESRS delegated act.
  • Commission source for the reporting-regime side of the comparison.
Show 4 more
  • Official Commission source for CSRD delegated and implementing acts.
  • Official source for CSRD delegated and implementing acts rather than CSDDD penalties.
  • Commission source for the CSRD reporting framework.
  • Official Commission source for CSRD delegated and implementing acts and the link to Directive 2022/2464.
"Directive 2022/2464 on corporate sustainability reporting"
More quoted passages
"Find links to implementing and delegated acts"
"empowers the Commission to adopt delegated and implementing acts"
"how competent authorities and market participants shall comply"
"corporate sustainability reporting"
commission.europa.eu2 citations
Referenced sections
  • Grounding describes CSRD reporting as data identification, collection, processing, verification, and publication.
  • Source showing the EU treats reporting requirements and due diligence requirements as related but distinct workstreams.
"data identification, collection, processing, verification and publication"
More quoted passages
"sustainability reporting and due diligence"
eur-lex.europa.eu
Referenced sections
  • Article 34 provides the sustainability-reporting assurance framework and investigation and sanction systems for assurance providers; Article 51 requires effective, proportionate, and dissuasive national penalties for infringements of national implementing provisions.
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