The broader Omnibus simplification is no longer merely a proposal. Directive (EU) 2026/470 was adopted on 24 February 2026, published on 26 February, and entered into force on 18 March 2026.
Directive (EU) 2025/794 remains part of the history, but Directive (EU) 2026/470 supplies the current scope and schedule.
Use the adopted 2026 text. It narrowed company scope, changed Article 8 scoping and partner-information rules, revised last-resort relationship measures and monitoring, removed the standalone Article 22 climate-plan duty, set a 3% maximum limit for pecuniary penalties, removed the uniform EU civil-liability test, moved to 26 July 2028, and set one 26 July 2029 application date for companies remaining in scope.
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4 of 4 questions
Question 1
Which status labels are correct?
COM(2025)80: historical stop-the-clock proposal.
Directive (EU) 2025/794: adopted stop-the-clock amendment, later superseded for the current schedule.
COM(2025)81: historical simplification proposal.
: adopted, binding simplification amendment and current source.
Member State measures: national law still to be monitored through the 26 July 2028 deadline.
Earlier adopted timing amendment retained as legislative history.
Question 2
What should teams correct now?
Do not apply the Commission's February 2025 proposal as if every proposed change became law. Build the change register from and the current consolidated . Preserve national-law dependencies because a directive requires and Member States retain room in areas the CSDDD does not fully harmonise.
Separate removed rules from amended rules. Article 22 was deleted. Article 29's uniform liability test was deleted, but compensation and procedural safeguards remain. Mandatory termination was removed, while restrictions on new or extended relationships, possible suspension, enhanced action plans, notice, impact comparison, monitoring, and review remain in amended Articles 10 and 11.
Also separate entry into force from company application. The 2026 amendment is binding on Member States, which must complete by 26 July 2028 and apply the national measures from 26 July 2029. Until then, a company's current duties may arise from existing national due diligence law, sector rules, contracts, or voluntary commitments rather than from the future application date alone.
Rerun scope using the amended 5,000-employee and EUR 1.5 billion routes.
Replace the old franchise and licensing thresholds with the amended EUR 75 million Union-royalty and EUR 275 million turnover route.
Replace 2027 and 2028 first-wave dates with 2028 transposition and 2029 application.
Revalidate due diligence controls against the amended articles rather than assuming COM(2025)81 and the final act are identical.
Relabel or retire the former Article 22 control.
Replace the superseded 5% penalty claim with the amended 3% maximum-limit rule, then perform national penalty analysis.
Do not describe civil liability as wholly deleted: national law supplies the liability conditions, while amended Article 29 retains full compensation, a five-year minimum limitation period, cost protection, injunctions, and proportionate disclosure.
Current consolidated text showing which original provisions remain and how the 2026 amendments read in context.
Question 3
Which operating controls changed?
The amendment changed how several controls operate, but it retained the core Articles 5 to 16 lifecycle. Covered companies still need a risk-based due diligence policy, impact identification and assessment, prioritisation where necessary, prevention and corrective measures, remediation, stakeholder engagement, complaint and notification routes, monitoring, and public communication under the applicable national measures.
Retain supporting evidence for at least five years from production or receipt, extending retention through any ongoing proceeding. Review and, where necessary, update the due diligence policy at least every 24 months and without undue delay after a significant change. These policy and evidence cycles are separate from the amended Article 15 effectiveness assessment, which runs after significant change, at least every five years, and on reasonable grounds to doubt adequacy or identify new risks.
Article 8 now starts with a scoping exercise based solely on reasonably available information, followed by in-depth assessment in areas where impacts are most likely and most severe.
In-depth partner requests must be necessary. For partners with fewer than 5,000 employees, the information may be requested only when it cannot reasonably be obtained by other means.
Articles 10 and 11 no longer require termination. They retain last-resort restrictions on new or extended relationships, possible suspension where governing law permits it, enhanced action plans, comparison of suspension impacts, reasonable notice, and review.
Article 15 monitoring moved to without undue delay after significant change, at least every five years, and whenever there are reasonable grounds to doubt adequacy or effectiveness or to identify new risks.
Article 18 now sets 26 July 2027 for Commission guidance on voluntary model contractual clauses; the general guidelines listed in Article 19 follow the amended 2027 and 2028 deadlines.
Article 16 reporting applies for financial years starting on or after 1 January 2030, and annual statements are submitted for ESAP access from 1 January 2031.
Current Articles 8, 10, 11, 15, 16, 17, 18, 19, 29, and 37 support the operating-control changes and dates listed here.
Question 4
What should an Omnibus change register retain?
For each old control, record the former source, the adopted amendment, the current consolidated article, the national-law dependency, the affected entity or process, and the implementation decision. Mark proposal text and legislative history as historical so a reviewer can tell which source has legal force.
The register should lead to an owner and a dated action, not a general statement that Omnibus was reviewed. Reassess it when a Member State publishes measures, the Commission issues Article 18 or 19 guidance, a group crosses or falls below a scope threshold for a relevant year, or a business process changes the .
Source status: proposal, adopted amending directive, consolidated , national , official guidance, or internal interpretation.
Legal effect: deleted, replaced, retained, delayed, or dependent on national law.
Control effect: retire, relabel, redesign, preserve, or create, with the reason and responsible owner.
Evidence: scope calculation, policy revision, process map, contract update, training record, complaint route, monitoring record, or public-statement correction.
Next trigger: national , Commission guidance, threshold change, significant operational change, new risk, or control-effectiveness concern.
Current text for Article 5 evidence retention, Article 7 policy updates, the Articles 8 to 16 due diligence lifecycle, guidance deadlines, and Article 37 application dates.
Reconcile old CSDDD controls with the adopted amendment
Create a change register showing each old claim, current provision, affected control, owner, and evidence update.
Current text for Article 5 evidence retention, Article 7 policy updates, the Articles 8 to 16 due diligence lifecycle, guidance deadlines, and Article 37 application dates.