--- title: "CSDDD FAQ: scope, dates, duties, liability, and evidence" canonical_url: "https://www.sorena.io/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items" source_url: "https://www.sorena.io/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items" author: "Sorena AI" description: "Practical answers on CSDDD scope, current application dates, chain of activities, due diligence duties, complaints, remediation, civil liability, climate plans, and evidence." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "CSDDD FAQ" - "Corporate Sustainability Due Diligence Directive" - "Directive (EU) 2024/1760" - "Directive (EU) 2025/794" - "CSDDD scope" - "chain of activities" - "due diligence" - "complaints procedure" - "remediation" - "civil liability" - "climate transition plan" - "CSDDD" - "EU Corporate Sustainability Due Diligence Directive" - "complaints" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # CSDDD FAQ: scope, dates, duties, liability, and evidence Practical answers on CSDDD scope, current application dates, chain of activities, due diligence duties, complaints, remediation, civil liability, climate plans, and evidence. *FAQ Hub* *CSDDD* *EU* ## CSDDD FAQ scope, duties, dates, liability, and evidence Answers to the practical questions teams ask when turning the Corporate Sustainability Due Diligence Directive into an operating program. Use this hub to separate legal scope, chain-of-activities mapping, adverse-impact controls, complaints, remediation, climate planning, and proof records. Directive (EU) 2024/1760 creates a due diligence framework for very large EU and non-EU companies. The practical work is to decide whether the entity is in scope, when national rules apply, which operations and business partners sit inside the chain of activities, which adverse impacts need action, and which evidence will prove the program works. ## Browse sub-FAQ modules ### [CSDDD chain of activities boundaries: upstream and downstream FAQ](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md) FAQ on how the CSDDD defines chain of activities boundaries for subsidiaries, direct and indirect business partners, upstream activities, downstream logistics, and evidence. - 6 items ### [CSDDD civil liability under Article 29: what companies should check](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/civil-liability.md) FAQ on CSDDD Article 29 civil liability: liability conditions, protected legal interests, causation, compensation, limitation periods, and evidence disclosure. - 4 items ### [CSDDD complaints and notifications FAQ](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md) FAQ on Article 14 CSDDD complaint and notification mechanisms, who may complain, follow-up rights, confidentiality, retaliation, and evidence. - 7 items ### [CSDDD contractual assurances FAQ for Articles 10 and 11](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/contractual-assurances.md) How CSDDD Articles 10 and 11 use contractual assurances with business partners, verification, SME support, action plans, and suspension or termination escalation. - 4 items ### [CSDDD franchising and licensing scope FAQ](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/franchising.md) FAQ on when franchise or licensing networks can fall within Article 2 of the EU CSDDD, including royalties, turnover, EU and non-EU treatment, and evidence. - 6 items ### [CSDDD non-EU turnover threshold FAQ](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/non-eu-turnover.md) How non-EU companies should assess CSDDD scope using EU-generated turnover, group thresholds, authorised representative records, and competent authority evidence. - 5 items ### [CSDDD Omnibus timing changes after Directive (EU) 2025/794](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/omnibus-current-date-changes.md) FAQ answer on current CSDDD Article 37 dates after Directive (EU) 2025/794 and how to separate adopted timing changes from proposal-stage Omnibus simplification. - 4 items ### [CSDDD prevention vs mitigation: potential and actual adverse impacts](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/prevention-vs-mitigation.md) CSDDD FAQ on when to prevent or mitigate potential adverse impacts, when to end or minimise actual adverse impacts, and what evidence records to keep. - 6 items ### [CSDDD remediation FAQ: when companies must remedy adverse impacts](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/remediation.md) FAQ on CSDDD remediation: when Article 12 requires remedy, how complaints and stakeholder engagement affect the response, and what evidence to keep. - 5 items ### [CSDDD risk prioritisation FAQ: severity, likelihood, and evidence](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/risk-prioritisation.md) How to prioritise CSDDD adverse impacts when teams cannot address everything at once, using severity, likelihood, stakeholder evidence, and a reviewable rationale. - 4 items ### [CSDDD scope waves: current Article 37 dates and thresholds](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/scope-waves.md) FAQ on the current CSDDD phase-in after Directive (EU) 2025/794: 26 July 2028, 26 July 2029, Article 2 scope thresholds, and evidence to retain. - 5 items ### [CSDDD transition plans FAQ: Article 22 climate plan requirements](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/transition-plans.md) FAQ on CSDDD Article 22 climate transition plans: targets, decarbonisation levers, investment and funding, governance, CSRD overlap, and evidence records. - 6 items ### [How CSDDD overlaps with OECD, UNGP, and ILO standards](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/oecd-ungp-and-ilo-overlap.md) FAQ on how OECD responsible business conduct guidance, the UN Guiding Principles, and ILO labour standards inform CSDDD due diligence without being the same legal instrument. - 5 items Browse all indexed questions: [/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items.md) ## All FAQ items *Page 1 of 4. Showing 20 of 67 items.* ### [What does chain of activities mean under the CSDDD?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md#what-does-chain-of-activities-mean-under-the-csddd) *Module: [CSDDD chain of activities boundaries: upstream and downstream](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md)* For CSDDD due diligence, start with three buckets: the company's own operations, the operations of its subsidiaries, and the operations of business partners where those partner activities are related to the company's chain of activities. - Map own operations and subsidiary operations separately from partner operations. - Classify each partner as upstream, downstream product logistics, or outside the CSDDD chain-of-activities definition. - Do not treat downstream customer use, general resale, product disposal, or downstream services as covered merely because they occur after sale. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - Article 3 defines chain of activities and distinguishes upstream production and service inputs from narrower downstream product distribution, transport, and storage. ### [Are subsidiaries inside the chain of activities boundary?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md#are-subsidiaries-inside-the-chain-of-activities-boundary) *Module: [CSDDD chain of activities boundaries: upstream and downstream](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md)* Subsidiaries are not just another supplier tier. The CSDDD repeatedly treats due diligence as covering a company's own operations, the operations of its subsidiaries, and, where related to the chain of activities, the operations of business partners. - Record each covered subsidiary, legal entity, activity, site, product line, and service line. - Show which parent-level due diligence elements apply to the subsidiary and which are handled locally. - Keep subsidiary evidence separate enough to respond to supervisory authority questions and civil-liability analysis. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - Articles 5, 6, and 8 support separate treatment of own operations, subsidiaries, business partners, and group-level due diligence support. ### [How should direct and indirect business partners be classified?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md#how-should-direct-and-indirect-business-partners-be-classified) *Module: [CSDDD chain of activities boundaries: upstream and downstream](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md)* A direct business partner is an entity with a commercial agreement related to the company's operations, products, or services, or an entity to which the company provides services. An indirect business partner is not the direct contracting party, but performs business operations related to the company's operations, products, or services. - Use contract records to identify direct business partners. - Use bills of material, logistics flows, service delivery maps, supplier disclosures, audit data, and complaints to identify indirect partners. - Flag indirect partners in high-risk geographies, sectors, product inputs, or logistics roles for deeper assessment rather than treating them as invisible tiers. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - Article 3 defines direct and indirect business partners; Articles 8, 10, and 11 show how partner classification drives mapping, assessment, assurances, verification, and measures. ### [Where do downstream distribution, transport, and storage stop?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md#where-do-downstream-distribution-transport-and-storage-stop) *Module: [CSDDD chain of activities boundaries: upstream and downstream](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md)* Downstream coverage is limited to distribution, transport, and storage of the company's product where a business partner carries out those activities for the company or on the company's behalf. It is not a general downstream customer, reseller, user, or end-of-life obligation. - Include downstream product logistics performed for the company or on its behalf. - Exclude downstream activities related to the company's services, and for regulated financial undertakings exclude downstream recipients of services and products. - Exclude product disposal from the CSDDD chain-of-activities boundary, while checking whether another product, waste, export-control, or sector law applies. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - Recitals 25 and 26 and Article 3 define downstream product logistics coverage and exclusions for product disposal, downstream services, regulated financial undertakings, and authorised export-controlled products. ### [What evidence should a CSDDD boundary decision retain?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md#what-evidence-should-a-csddd-boundary-decision-retain) *Module: [CSDDD chain of activities boundaries: upstream and downstream](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md)* Keep evidence that proves why each activity is in scope, out of scope, or unresolved. A useful boundary record links the legal definition to the company's actual product, service, subsidiary, supplier, logistics, and partner facts. - Boundary matrix with columns for entity, activity, product or service, upstream or downstream classification, direct or indirect partner status, inclusion decision, source citation, and reviewer. - Product and service flow evidence: bills of material, sourcing maps, logistics routes, warehouse contracts, distributor contracts, service delivery diagrams, and subsidiary activity descriptions. - Risk evidence: sector, geography, product, service, business-operation, and complaint data used to decide where adverse impacts are most likely or most severe. - Action evidence: prevention action plans, contractual assurances, verification records, SME support decisions, suspension or termination reviews, and monitoring updates where the boundary decision triggered CSDDD measures. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - Articles 5, 8, 10, and 11 support mapping, assessment, prevention, mitigation, and actual-impact records tied to own operations, subsidiaries, and chain-of-activities business partners. ### [What is the most common mistake with CSDDD chain-of-activities boundaries?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md#what-is-the-most-common-mistake-with-csddd-chain-of-activities-boundaries) *Module: [CSDDD chain of activities boundaries: upstream and downstream](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/chain-of-activities-boundaries.md)* The most common mistake is using a broad value-chain diagram as if every actor in it is automatically inside the CSDDD chain of activities. The directive's wording is more specific: upstream is tied to production of goods or provision of services, while downstream is limited to product distribution, transport, and storage performed for the company or on its behalf. - Do not include product disposal unless another legal regime separately requires disposal controls. - Do not include downstream service recipients as if they were downstream product logistics providers. - Do not rely only on first-tier supplier lists when indirect partners perform activities tied to high-risk production, sourcing, manufacture, transport, storage, or supply. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - The directive's definitions and recitals support a bounded chain-of-activities analysis rather than an unlimited value-chain interpretation. ### [When can CSDDD Article 29 create civil liability?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/civil-liability.md#when-can-csddd-article-29-create-civil-liability) *Module: [CSDDD civil liability under Article 29: what companies should check](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/civil-liability.md)* Article 29 says Member States must ensure that a company can be held liable for damage caused to a natural or legal person only when two core conditions are met. First, the company intentionally or negligently failed to comply with the CSDDD duties in Articles 10 and 11, and the relevant right, prohibition, or obligation in the Directive Annex is aimed at protecting that person. Second, that failure caused damage to the person's legal interests that are protected under national law. - Duty: identify whether the alleged failure concerns prevention, mitigation, bringing an actual impact to an end, or minimising its extent under Articles 10 or 11. - Fault: record why the issue is alleged to be intentional or negligent, rather than only a difficult prioritisation or monitoring judgement. - Protected interest: map the alleged harm to a natural or legal person's legal interest protected under national law. - Causation: document whether the damage resulted from the company failure, not only from a business partner's conduct. Sources for this answer: - [Directive (EU) 2024/1760 Article 29 on civil liability](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 29 sets the CSDDD civil-liability conditions: an intentional or negligent failure to comply with Articles 10 and 11, protected legal-interest damage, causation, full compensation, limitation-period safeguards, and evidence disclosure rules. ### [What limits should teams remember before making liability claims?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/civil-liability.md#what-limits-should-teams-remember-before-making-liability-claims) *Module: [CSDDD civil liability under Article 29: what companies should check](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/civil-liability.md)* Article 29 contains important limits. A company cannot be held liable under Article 29 where the damage was caused only by its business partners in the chain of activities. Participation in industry initiatives, multi-stakeholder initiatives, third-party verification, or contractual clauses also does not automatically protect a company from liability, but those measures may still be relevant evidence of how the company implemented due diligence. - Do not state that Article 29 creates liability for every supplier-caused impact; check whether company conduct is part of the causal chain. - Do not treat certificates, audits, contractual clauses, or initiative membership as a complete defence; keep the underlying due diligence evidence. - Do not mix damages with CSDDD administrative penalties; Article 29 compensation is not a fine. Sources for this answer: - [Directive (EU) 2024/1760 Article 29 on civil liability](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 29 sets the CSDDD civil-liability conditions: an intentional or negligent failure to comply with Articles 10 and 11, protected legal-interest damage, causation, full compensation, limitation-period safeguards, and evidence disclosure rules. ### [What compensation and limitation-period rules does Article 29 require?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/civil-liability.md#what-compensation-and-limitation-period-rules-does-article-29-require) *Module: [CSDDD civil liability under Article 29: what companies should check](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/civil-liability.md)* If a company is held liable under Article 29, the injured natural or legal person has the right to full compensation in accordance with national law. The same paragraph states that full compensation must not lead to overcompensation through punitive, multiple, or other types of damages. - Compensation: frame the issue as full compensation for damage, not punitive damages or a penalty claim. - Limitation period: use at least five years as the Article 29 floor, then check the implementing Member State law for the actual forum rule. - Start point: record when the alleged infringement ceased and when the claimant could reasonably know the harm and infringer. Sources for this answer: - [Directive (EU) 2024/1760 Article 29 on civil liability](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 29 sets the CSDDD civil-liability conditions: an intentional or negligent failure to comply with Articles 10 and 11, protected legal-interest damage, causation, full compensation, limitation-period safeguards, and evidence disclosure rules. ### [What evidence should companies preserve for an Article 29 dispute?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/civil-liability.md#what-evidence-should-companies-preserve-for-an-article-29-dispute) *Module: [CSDDD civil liability under Article 29: what companies should check](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/civil-liability.md)* Article 29 expects evidence to matter. When a claimant provides a reasoned justification with reasonably available facts and evidence supporting the plausibility of a damages claim, and indicates that additional evidence is controlled by the company, courts must be able to order company disclosure under national procedural law. - Impact file: identified potential or actual adverse impact, affected right or prohibition, protected person group, severity, likelihood, and prioritisation rationale. - Action file: Article 10 or 11 measures selected, owners, deadlines, supplier engagement, remediation or mitigation steps, and follow-up results. - Causation file: evidence showing whether the alleged harm followed from company conduct, joint conduct, or business-partner-only conduct. - Disclosure file: preserve relevant records in a searchable form and flag confidentiality issues before litigation or authority requests arise. Sources for this answer: - [Directive (EU) 2024/1760 Article 29 on civil liability](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 29 sets the CSDDD civil-liability conditions: an intentional or negligent failure to comply with Articles 10 and 11, protected legal-interest damage, causation, full compensation, limitation-period safeguards, and evidence disclosure rules. ### [What does Article 14 require companies to set up?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md#what-does-article-14-require-companies-to-set-up) *Module: [CSDDD complaints and notifications](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md)* Article 14 requires a notification mechanism and a complaints procedure. The complaint route is for listed people and organisations that have legitimate concerns about actual or potential adverse impacts connected to the company's own operations, subsidiaries, or business partners in its chain of activities. - Publish the complaint route where affected people, representatives, unions, and experienced civil society organisations can find it. - Accept complaints about actual or potential human rights and environmental adverse impacts within the Article 14 scope. - Define how the company assesses whether a complaint is founded or unfounded. - Route well-founded complaints into the company's due diligence actions under Articles 10, 11, and 12. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 14 sets the notification mechanism and complaints procedure requirements, including the qualities of the procedure and consequences of a well-founded complaint. - [EUR-Lex summary: Corporate sustainability due diligence](https://data.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - The EUR-Lex summary confirms that due diligence includes accessible public notification and complaints procedures with appropriate follow-up. ### [Who may submit a CSDDD complaint?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md#who-may-submit-a-csddd-complaint) *Module: [CSDDD complaints and notifications](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md)* Article 14 lists three groups. First, natural or legal persons who are affected, or have reasonable grounds to believe they might be affected, by an adverse impact may complain. Their legitimate representatives, including civil society organisations and human rights defenders, may complain on their behalf. - Affected people and legal persons, including those with reasonable grounds to believe they might be affected. - Legitimate representatives acting on behalf of affected people, such as civil society organisations or human rights defenders. - Trade unions and other workers' representatives for people working in the relevant chain of activities. - Experienced civil society organisations for complaints about related environmental adverse impacts. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 14(2) identifies who may submit complaints to a company under the CSDDD complaints procedure. ### [What is a legitimate concern, and what evidence helps?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md#what-is-a-legitimate-concern-and-what-evidence-helps) *Module: [CSDDD complaints and notifications](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md)* The Directive uses the phrase legitimate concerns for complaints about actual or potential adverse impacts. It does not require the complainant to prove the case like a court claim before the company accepts the complaint, but the concern should be tied to a plausible adverse impact and to the company's operations, subsidiaries, or chain-of-activities business partners. - Capture enough facts to test Article 14 scope without demanding unnecessary proof at intake. - Separate evidence supplied by the complainant from facts the company later verifies through due diligence. - Record the company's reasoning when the complaint is treated as founded or unfounded. - If founded, document the link to identified impacts and the measures taken or planned. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 14(1) frames complaints around legitimate concerns about actual or potential adverse impacts tied to the company and its chain of activities. ### [What follow-up rights do complainants have?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md#what-follow-up-rights-do-complainants-have) *Module: [CSDDD complaints and notifications](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md)* Complainants have explicit Article 14 follow-up rights. They may request appropriate follow-up from the company, meet company representatives at an appropriate level to discuss actual or potential severe adverse impacts and potential remediation, and receive reasons for why the complaint was considered founded or unfounded. - Acknowledge and triage the complaint through a defined procedure. - Offer appropriate follow-up and escalation to representatives able to discuss severe impacts and remediation. - Give reasons for a founded or unfounded outcome. - For founded complaints, provide information on steps already taken or planned. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 14(4) gives complainants rights to appropriate follow-up, meetings, reasons, and information on steps where the complaint is founded. ### [How do confidentiality, anonymity, and non-retaliation work?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md#how-do-confidentiality-anonymity-and-non-retaliation-work) *Module: [CSDDD complaints and notifications](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md)* For complaints, companies must take reasonably available measures to prevent retaliation by ensuring the confidentiality of the complainant's identity in accordance with national law. If information needs to be shared, it must be shared in a way that does not endanger the complainant's safety, including by not disclosing that identity. - Ask at intake whether the person wants confidentiality or anonymity where available. - Restrict identity access to personnel who need it for handling and safety. - Do not disclose identity when sharing information if disclosure could endanger the complainant. - Keep retaliation controls documented, including access logs, redactions, and safety decisions. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 14(3) and 14(5) require confidentiality and reasonably available measures to prevent retaliation for complaint and notification channels. - [EUR-Lex summary: Corporate sustainability due diligence](https://data.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - The EUR-Lex summary confirms that individuals and organisations may raise concerns anonymously and confidentially under national law. ### [How is a complaint different from a notification or substantiated concern?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md#how-is-a-complaint-different-from-a-notification-or-substantiated-concern) *Module: [CSDDD complaints and notifications](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md)* A complaint is submitted to the company by the Article 14 complainant groups when they have legitimate concerns about actual or potential adverse impacts. A notification is also submitted to the company, but it is framed more broadly for persons and entities that have information or concerns about actual or potential adverse impacts. - Complaint: company channel for listed complainants with legitimate concerns about adverse impacts. - Notification: company channel for information or concerns, with anonymous or confidential submission where national law allows. - Substantiated concern: supervisory-authority route based on objective circumstances suggesting non-compliance. - Do not make company-channel use a condition for access to authority, court, or other non-judicial routes. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 14 distinguishes complaints and notifications, while Article 26 defines substantiated concerns submitted to supervisory authorities. - [EUR-Lex summary: Corporate sustainability due diligence](https://data.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - The EUR-Lex summary describes supervisory authorities receiving and acting on substantiated concerns. ### [What records should a company keep for Article 14 complaints?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md#what-records-should-a-company-keep-for-article-14-complaints) *Module: [CSDDD complaints and notifications](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/complaints.md)* The useful evidence file is a case file, not a generic policy attachment. It should prove that the channel was public and accessible, the correct complainant and impact questions were assessed, confidentiality and safety were handled, follow-up rights were respected, and founded complaints were connected to due diligence measures. - Public procedure, intake form, language/accessibility notes, and worker or union communication records. - Complaint or notification intake record, including complainant category, alleged impact, affected operations or chain-of-activities link, and confidentiality request. - Triage and assessment record explaining whether the matter is founded, unfounded, outside Article 14, or better routed as a notification. - Follow-up record covering acknowledgements, meetings, reasons provided, and steps or actions taken or planned. - Retaliation-prevention evidence, such as identity controls, redactions, restricted-access logs, and safety decisions. - Due diligence linkage showing any identified impact and the related Article 10, 11, or 12 measures. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 14 supplies the case-handling requirements, and the Directive's monitoring provisions include notifications and complaints in compliance documentation. - [EUR-Lex summary: Corporate sustainability due diligence](https://data.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - The EUR-Lex summary states that companies must keep due-diligence compliance documentation for at least five years. ### [When should CSDDD teams seek contractual assurances from business partners?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/contractual-assurances.md#when-should-csddd-teams-seek-contractual-assurances-from-business-partners) *Module: [CSDDD contractual assurances FAQ for Articles 10 and 11](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/contractual-assurances.md)* For potential adverse impacts, Article 10 requires companies to take appropriate measures to prevent or adequately mitigate impacts identified through due diligence. One relevant measure is seeking contractual assurances from a direct business partner that it will comply with the company's code of conduct and, where needed, a prevention action plan. - Use Article 10 assurances when the issue is a potential adverse impact that must be prevented or mitigated. - Use Article 11 assurances when the issue is an actual adverse impact that must be ended, minimised, and, where relevant, remediated. - Tie each assurance to the specific code-of-conduct obligation, prevention action plan, or corrective action plan it is meant to support. - Do not ask for generic supply-chain promises when the due-diligence finding points to a narrower activity, site, product line, sourcing practice, or business partner. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://data.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - Article 10(2)(b) and 10(4) support when contractual assurances are relevant for preventing or mitigating potential adverse impacts. - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Article 11(3)(c) and 11(5) support using contractual assurances for actual adverse impacts and corrective action plans. ### [What must sit alongside CSDDD contractual assurances?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/contractual-assurances.md#what-must-sit-alongside-csddd-contractual-assurances) *Module: [CSDDD contractual assurances FAQ for Articles 10 and 11](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/contractual-assurances.md)* A signed clause is not enough. Articles 10(5) and 11(6) say contractual assurances must be accompanied by appropriate measures to verify compliance. The directive allows independent third-party verification, including through industry or multi-stakeholder initiatives, where that is appropriate. - Assurance text mapped to the code of conduct, prevention action plan, or corrective action plan. - Verification method, such as documentary review, site assessment, third-party verification, or initiative-based verification where appropriate. - Improvement indicators and timelines from the prevention or corrective action plan. - Escalation trigger for missed milestones, unreliable evidence, refusal to cooperate, or persistent adverse impact. - Evidence showing the company kept monitoring instead of relying on paper-only assurances. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://data.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - Articles 10(5) and 11(6) require contractual assurances to be accompanied by appropriate verification measures. - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Recital 66 explains that contractual assurances alone do not satisfy CSDDD due-diligence standards. ### [How should companies handle SMEs in CSDDD contractual-assurance requests?](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/contractual-assurances.md#how-should-companies-handle-smes-in-csddd-contractual-assurance-requests) *Module: [CSDDD contractual assurances FAQ for Articles 10 and 11](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/contractual-assurances.md)* SMEs are not brought into the CSDDD scope merely because a large in-scope company asks for assurances, but Articles 10 and 11 protect SMEs in the assurance process. When assurances are obtained from, or a contract is entered into with, an SME, the terms must be fair, reasonable, and non-discriminatory. - Check whether the business partner is an SME before issuing standard assurance language. - Remove one-sided terms that push all verification cost, timing pressure, or implementation burden onto the SME. - Document whether capacity-building, training, management-system support, or financial support is needed. - Where independent third-party verification is carried out for an SME, record who pays and whether the SME may share verification results with other companies. Sources for this answer: - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://data.europa.eu/eli/dir/2024/1760/oj/eng?ref=sorena.io) - Articles 10(5) and 11(6) require SME contract terms to be fair, reasonable, and non-discriminatory. - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Articles 10(2)(e) and 11(3)(f) identify targeted and proportionate SME support measures. ## FAQ Pagination - Canonical index (page 1): [/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items.md) - Page 1 rule: `/page/1` is intentionally not generated; use the canonical index markdown URL. - Current page: 1 of 4 Pages: [1](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items.md) | [2](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items/page/2.md) | [3](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items/page/3.md) | [4](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items/page/4.md) [Next page](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/items/page/2.md) *Recommended next step* *Placement: after evidence section* ## Turn CSDDD answers into evidence Use the CSDDD FAQ to convert scope, chain-of-activities, impact, complaints, remediation, liability, and climate-plan decisions into traceable records. - [Open Research Copilot](/solutions/research-copilot.md): Answer CSDDD implementation questions with cited source material. - [Discuss CSDDD implementation](/contact.md): Review CSDDD scope, evidence, and operating-model gaps with Sorena. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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