EU CSDDD (Directive (EU) 2024/1760) Frequently asked questions

The Directive entered into force on 25 July 2024, but company level application is phased. After Directive (EU) 2025/794, Member States transpose by 26 July 2027, the first wave applies from 26 July 2028, and broader application follows from 26 July 2029.

If you still have internal material showing a 26 July 2026 transposition deadline or a 26 July 2027 first wave, update it.

EU companies are mainly captured when they have more than 1000 employees and more than EUR 450 million worldwide turnover. Non-EU companies are captured mainly through more than EUR 450 million Union turnover. There is also a separate franchising and licensing route using EUR 22.5 million royalties and EUR 80 million turnover.

Group structure matters because ultimate parent companies and designated subsidiaries can be relevant to how duties are performed.

No. The chain of activities includes certain downstream distribution, transport, and storage activities for products where the partner acts for the company or on its behalf. It does not include product disposal and it does not include downstream partners related to the services of the company.

That boundary should be recorded clearly because it shapes supplier outreach and complaint routing.

Yes. CSRD reporting can remove the separate Article 16 annual statement burden and can satisfy the adoption step of the Article 22 transition plan, but it does not remove the operational due diligence duties under Articles 7 to 15 or the duty to put the transition plan into effect.

In short, reporting can reduce duplication, but it does not replace the due diligence program.

Member States must provide penalties that are effective, proportionate, and dissuasive. When pecuniary penalties are imposed, the maximum limit must be at least 5 percent of net worldwide turnover. The Directive also includes civil liability rules where a company intentionally or negligently fails to comply with certain obligations and that failure causes damage to a natural or legal person.

A company cannot be held liable if the damage was caused only by its business partners. National law will still matter heavily once Member States transpose the Directive.