EU CSDDD (Directive (EU) 2024/1760) Compared with German LkSG

The LkSG applies to companies with a certain employee count in Germany. The threshold moved to 1000 employees from 1 January 2024. The CSDDD uses different triggers: more than 1000 employees plus more than EUR 450 million worldwide turnover for EU companies, and more than EUR 450 million Union turnover for non-EU companies, plus separate franchising and licensing triggers.

So an LkSG scope memo is not enough to answer the CSDDD scope question, especially for groups with non-German entities, heavy franchise models, or large Union turnover outside Germany.

Both regimes are risk based and supplier focused, but the CSDDD uses the defined chain-of-activities concept with specific upstream and downstream boundaries. That definition includes certain downstream product distribution activities but excludes product disposal and excludes downstream services.

A German program built around the LkSG supply chain concept should be remapped against the CSDDD chain definition rather than copied without review.

The CSDDD introduces an explicit Article 22 transition plan duty aligned with 1.5 C and climate neutrality objectives. The LkSG does not contain the same standalone climate transition plan requirement.

The CSDDD also has its own annual statement and ESAP mechanics, although companies already reporting under the CSRD can be exempt from the standalone annual statement.

The CSDDD creates a Union supervisory cooperation framework, allows substantiated concerns to be raised with supervisory authorities, requires penalties with a maximum cap not less than 5 percent of net worldwide turnover, and includes civil liability rules. Those features make the EU regime broader than a simple copy of existing German compliance routines.

An LkSG program remains valuable, but it needs to be hardened for cross border supervision, Article 29 civil liability analysis, and greater focus on the design and traceability of due diligence decisions.