CSDDDCalendarEU

CSDDD deadlines and compliance calendar

A source-linked calendar for the EU Corporate Sustainability Due Diligence Directive after the Article 37 amendments made by Directive (EU) 2025/794.

Use it to separate the directive's entry into force, Member State transposition, company application phases, Article 16 reporting timing, and Commission guidance milestones.

Author
Sorena AI
Published
May 9, 2026
Updated
May 25, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
2

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 25, 2026
Overview

The CSDDD entered into force on 25 July 2024. The current consolidated EUR-Lex text shows Directive (EU) 2025/794 amending Article 37, so the operative calendar now uses a 26 July 2027 transposition deadline, 26 July 2028 first application phase, and 26 July 2029 second application phase. This page turns those dates into a practical calendar that legal, sustainability, procurement, and reporting teams can use without relying on the pre-amendment schedule.

Recommended next step

Build a CSDDD calendar from entity evidence

Use this CSDDD calendar to connect each entity's Article 37 cohort, Article 16 reporting path, guidance checkpoints, and evidence owners before national transposition measures apply.

Section 2

Article 37 application phases after Directive (EU) 2025/794

Build the company-facing calendar by cohort, not by a single universal due date. Article 37 now gives Member States until 26 July 2027 to transpose the Directive and then applies national measures in two main waves.

The first wave starts on 26 July 2027 for large EU companies and parent companies above the Article 37 point (a) threshold, and for large non-EU companies above the Article 37 point (b) Union turnover threshold. The second wave starts on 26 July 2028 for the next cohort, and on 26 July 2029 for the remaining companies covered by the Article 2 scope provisions, including the franchise and licensing categories referenced in Article 37 point (c).

  • 26 July 2027: EU companies and parent companies in Article 2(1)(a) and (b) with more than 5,000 employees on average and more than EUR 1.5 billion net worldwide turnover in the relevant financial year; Article 16 measures apply to those companies for financial years starting on or after 1 January 2028.
  • 26 July 2027: third-country companies in Article 2(2)(a) and (b) with more than EUR 1.5 billion net turnover in the Union in the relevant financial year; Article 16 measures apply to those companies for financial years starting on or after 1 January 2028.
  • 26 July 2028: EU companies and parent companies in Article 2(1)(a) and (b) with more than 3,000 employees on average and more than EUR 900 million net worldwide turnover in the relevant financial year.
  • 26 July 2028: third-country companies in Article 2(2)(a) and (b) with more than EUR 900 million net turnover in the Union in the relevant financial year.
  • 26 July 2029: all other companies covered by Article 2(1)(a) and (b), Article 2(2)(a) and (b), and the franchise or licensing categories in Article 2(1)(c) and Article 2(2)(c); Article 16 measures apply to those companies for financial years starting on or after 1 January 2029.
  • Practical evidence to keep: entity list, group parent analysis, employee average calculation, worldwide and Union turnover support, franchise or licensing royalty support, and the Article 37 cohort assigned to each entity.
Section 3

Article 16 reporting dates and exceptions

Article 16 is a separate calendar track. Companies that must publish an Article 16 annual statement do so on their website within a reasonable period and no later than 12 months after the balance sheet date for the financial year covered by the statement, unless they voluntarily report under Directive 2013/34/EU and publish by the annual-financial-statement date.

Article 16 also contains an important exception: the annual-statement obligation does not apply to companies already subject to sustainability reporting requirements under Article 19a, 29a, or 40a of Directive 2013/34/EU, including specified exemptions under that Directive. Under amended Article 37, Member States apply the Article 16 measures later than the first general application dates: financial years starting on or after 1 January 2028 for the 26 July 2027 cohort, and financial years starting on or after 1 January 2029 for the 26 July 2028 and 26 July 2029 cohorts.

  • 31 March 2027: the Commission must adopt delegated acts setting Article 16 reporting content and criteria.
  • For Article 16 annual statements, record the relevant balance sheet date and the latest 12-month publication deadline.
  • For companies voluntarily reporting under Directive 2013/34/EU, align the Article 16 publication date with the annual financial statements date.
  • For companies reporting under Directive 2013/34/EU Articles 19a, 29a, or 40a, record the reporting basis for the Article 16 paragraph 2 exception.
  • From 1 January 2029: Article 17 requires simultaneous ESAP submission when making public the Article 16 annual statement.
Section 4

Commission guidance milestones to track

The CSDDD calendar is not only about company application dates. Articles 18 and 19 require Commission support materials that should feed supplier contract updates, risk assessment methods, stakeholder engagement procedures, remediation design, and transition-plan planning.

Do not wait for every guidance item before starting evidence collection. The practical move is to reserve review checkpoints in 2027 so the compliance program can absorb model clauses, due diligence guidance, risk-factor guidance, transition-plan guidance, resource-sharing guidance, and stakeholder guidance when they are issued.

  • 26 January 2027: voluntary model contractual clause guidance under Article 18.
  • 26 January 2027: Article 19 guidance on due diligence practices, risk factors, data sources, and digital tools.
  • 26 July 2027: Article 19 guidance on transition plans, resource sharing, and stakeholder engagement.
  • Calendar evidence: guidance owner, affected internal policy or contract template, implementation decision, version date, and a record of what changed after each Commission guidance release.
Section 5

Practical compliance calendar evidence

A useful CSDDD calendar should be auditable. Each date should connect to a cohort, legal article, internal owner, affected artifact, and evidence file. That matters because supervisory authorities will enforce national transposition measures, and because Article 24 requires Member States to designate authorities for obligations under Articles 7 to 16 and Article 22.

For each covered entity, keep a calendar row that shows why the date applies and what will be ready by that date. The row should be specific enough for finance, legal, sustainability, procurement, and operations teams to act from the same record.

  • Entity and group scope: legal entity, parent status, EU or third-country status, relevant Article 2 limb, employee average, net worldwide turnover, net Union turnover, and franchise or licensing facts if relevant.
  • Cohort and date: Article 37 point (a), (b), or (c); transposition watch owner; first application date; Article 16 reporting-year date; and next reassessment trigger.
  • Due diligence artifacts: policy integration record, risk identification method, prioritisation record, prevention or corrective action plan, remediation route, complaints procedure, monitoring review, and stakeholder engagement log.
  • Reporting artifacts: Article 16 exemption analysis, annual-statement owner, balance sheet date, delegated-act watch item, ESAP submission owner from 2029, and Directive 2013/34/EU reporting cross-reference if used.
  • Guidance update controls: model-clause review, transition-plan review, data-source review, stakeholder-engagement update, and evidence of any policy or template changes after Commission guidance is published.
Primary sources

References and citations

commission.europa.eu
Referenced sections
  • Supports the Directive entry-into-force date and the core due diligence duty described by the Commission.
"new rules establishing a corporate due diligence duty enter into force"
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