CSDDD vs CSRD due diligence and reporting compared
CSDDD is an operational due diligence regime for human rights and environmental adverse impacts. CSRD is a sustainability reporting regime built around management-report disclosure and ESRS standards.
This comparison helps keep duties, evidence, reporting, timing, and enforcement separate while reusing data where the same facts genuinely support both regimes.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
evidence should prove reportable sustainability information: data sources, materiality judgements, disclosures, controls over the sustainability statement, and alignment with the applicable requirements.
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 .
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.
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.
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.
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.
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.
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.
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?
Use when the question is: what sustainability information must the undertaking report, under which standard, for which financial year, and with what reporting controls?
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.
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.
/ 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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
evidence should prove reportable sustainability information: data sources, materiality judgements, disclosures, controls over the sustainability statement, and alignment with the applicable requirements.
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 .
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.
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.
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.
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.
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.
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.
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?
Use when the question is: what sustainability information must the undertaking report, under which standard, for which financial year, and with what reporting controls?
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.
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.
/ 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.
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.
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.
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.
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.
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.
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"