Under the CSDDD, prevention and mitigation are mainly the Article 10 response to potential adverse impacts. Article 11 applies once an adverse impact is actual: the company must bring it to an end or, if that cannot happen immediately, minimise its extent.
This page helps separate potential-impact controls, actual-impact corrective actions, stakeholder engagement, monitoring, and evidence records.
Structured answer sets in this page tree.
Cited legal and guidance references.
Treat prevention, mitigation, ending an impact, and minimising an impact as distinct responses. The Directive separates the work by impact status: identify and prioritise actual and , prevent or adequately mitigate potential adverse impacts, and bring to an end or minimise their extent where they cannot immediately be ended. Directive (EU) 2026/470 entered into force on 18 March 2026, but Member States must transpose its CSDDD amendments by 26 July 2028 and apply them from 26 July 2029. Until then, check the national law that currently governs the company.
Compare the response for with the response for .
Article 10 work: prevent the impact where possible, or adequately mitigate it where prevention is not possible or not immediately possible.
Article 11 work: bring the impact to an end, or minimise its extent where it cannot immediately be brought to an end.
| Dimension | Potential adverse impact | Actual adverse impact | Operational implication |
|---|---|---|---|
| Scope boundary | A potential adverse human-rights or environmental impact is identified under Article 8 and then prioritised under Article 9. | An actual adverse human-rights or environmental impact is identified under Article 8 and then prioritised under Article 9. | Separate the status first. Article 10 is for potential impacts, while Article 11 applies once the impact is actual. |
| Required response | Prevent the potential impact; where prevention is not possible or not immediately possible, adequately mitigate it. | Bring the actual impact to an end; where it cannot immediately be ended, minimise its extent. | Write the objective in operational terms: avoided, reduced likelihood or severity, ended, or minimised. |
| Trigger | Use a prevention action plan where the nature or complexity of the prevention measures requires one, with defined timelines and indicators. | Use a corrective action plan where the actual impact cannot immediately be brought to an end, with defined timelines and indicators. | Keep plan names aligned with the impact status so records, supplier asks, and monitoring indicators are not misleading. |
| Core obligations | Measures can include contractual assurances with verification, investments, operational or purchasing-practice changes, design and distribution changes, SME support, and collaboration. | Measures can include neutralising or minimising the impact, a corrective action plan, contractual assurances with verification, investments, operational changes, SME support, collaboration, and remediation. | Do not treat supplier clauses as the only control; match measures to involvement, influence, severity, and what would change the impact. |
| Evidence record | Keep the Article 8 mapping, Article 9 priority rationale, prevention action plan, verification records, SME support evidence, stakeholder input, and monitoring indicators. | Keep the actual-impact finding, corrective action plan, minimisation or ending evidence, remediation assessment, stakeholder input, complaint or notification records, and monitoring indicators. | A useful file proves the classification, the selected measures, the implementation status, and whether measures remained adequate and effective over time. |
| Timing and deadlines | If a potential impact cannot be prevented or adequately mitigated, amended Article 10 requires no new or extended relationship, an enhanced prevention action plan where success can reasonably be expected, and suspension where the governing law allows it unless the impact comparison supports the exception. | If an actual impact cannot be ended or minimised, amended Article 11 requires no new or extended relationship, an enhanced corrective action plan where success can reasonably be expected, and suspension where the governing law allows it unless the impact comparison supports the exception. | Before suspension, assess whether its adverse impacts could be manifestly more severe than the unresolved impact. The 2026 amendment removed mandatory termination but retained conditional suspension. |
| Enforcement | National rules implementing Article 10 must require companies to prevent potential impacts or adequately mitigate them where prevention is not possible or not immediately possible. | National rules implementing Article 11 must require companies to end actual impacts or minimise their extent where they cannot immediately be ended. | A plan must match the impact status and the article that applies. The amended rules are due to apply through national law from 26 July 2029. |
| Overlap and reuse | Potential-impact work can still later become an actual-impact file if the risk materialises. | Actual-impact work should not be documented as a prevention file, even if some controls are reused. | Reuse tools and evidence where helpful, but keep the legal classification and the plan name aligned with the real status of the impact. |
| Practical decision rule | If the issue is still only a risk, use Article 10 and document prevention or mitigation measures. | If the harm is already happening or happened, use Article 11 and document ending, minimisation, and remediation steps where relevant. | Check the facts first, then pick the article. If you are still classifying the event, do not copy the same wording into both sides of the comparison. |
A potential adverse human-rights or environmental impact is identified under Article 8 and then prioritised under Article 9.
An actual adverse human-rights or environmental impact is identified under Article 8 and then prioritised under Article 9.
Separate the status first. Article 10 is for potential impacts, while Article 11 applies once the impact is actual.
Prevent the potential impact; where prevention is not possible or not immediately possible, adequately mitigate it.
Bring the actual impact to an end; where it cannot immediately be ended, minimise its extent.
Write the objective in operational terms: avoided, reduced likelihood or severity, ended, or minimised.
Use a prevention action plan where the nature or complexity of the prevention measures requires one, with defined timelines and indicators.
Use a corrective action plan where the actual impact cannot immediately be brought to an end, with defined timelines and indicators.
Keep plan names aligned with the impact status so records, supplier asks, and monitoring indicators are not misleading.
Measures can include contractual assurances with verification, investments, operational or purchasing-practice changes, design and distribution changes, SME support, and collaboration.
Measures can include neutralising or minimising the impact, a corrective action plan, contractual assurances with verification, investments, operational changes, SME support, collaboration, and remediation.
Do not treat supplier clauses as the only control; match measures to involvement, influence, severity, and what would change the impact.
Keep the Article 8 mapping, Article 9 priority rationale, prevention action plan, verification records, SME support evidence, stakeholder input, and monitoring indicators.
Keep the actual-impact finding, corrective action plan, minimisation or ending evidence, remediation assessment, stakeholder input, complaint or notification records, and monitoring indicators.
A useful file proves the classification, the selected measures, the implementation status, and whether measures remained adequate and effective over time.
If a potential impact cannot be prevented or adequately mitigated, amended Article 10 requires no new or extended relationship, an enhanced prevention action plan where success can reasonably be expected, and suspension where the governing law allows it unless the impact comparison supports the exception.
If an actual impact cannot be ended or minimised, amended Article 11 requires no new or extended relationship, an enhanced corrective action plan where success can reasonably be expected, and suspension where the governing law allows it unless the impact comparison supports the exception.
Before suspension, assess whether its adverse impacts could be manifestly more severe than the unresolved impact. The 2026 amendment removed mandatory termination but retained conditional suspension.
National rules implementing Article 10 must require companies to prevent potential impacts or adequately mitigate them where prevention is not possible or not immediately possible.
National rules implementing Article 11 must require companies to end actual impacts or minimise their extent where they cannot immediately be ended.
A plan must match the impact status and the article that applies. The amended rules are due to apply through national law from 26 July 2029.
Potential-impact work can still later become an actual-impact file if the risk materialises.
Actual-impact work should not be documented as a prevention file, even if some controls are reused.
Reuse tools and evidence where helpful, but keep the legal classification and the plan name aligned with the real status of the impact.
If the issue is still only a risk, use Article 10 and document prevention or mitigation measures.
If the harm is already happening or happened, use Article 11 and document ending, minimisation, and remediation steps where relevant.
Check the facts first, then pick the article. If you are still classifying the event, do not copy the same wording into both sides of the comparison.
Under the , prevention is the first Article 10 objective for a potential adverse impact: stop the impact from occurring where possible. Mitigation is the Article 10 fallback where prevention is not possible or not immediately possible: reduce the likelihood, severity, or conditions that could allow the potential impact to occur.
For , the vocabulary changes. Article 11 requires companies to bring each impact to an end. If an impact cannot immediately be brought to an end, the company must minimise its extent and use corrective measures proportionate to the severity of the impact and the company's implication in it.
Binding current amendment for CSDDD scope, due diligence, monitoring, enforcement, and status changes discussed on this page.
Article 10 covers preventing or adequately mitigating potential adverse impacts; Article 11 covers bringing actual adverse impacts to an end or minimising their extent.
The EUR-Lex summary describes the CSDDD due diligence duty as addressing potential and actual human-rights and environmental adverse impacts.
Start with the amended Article 8 process. Use reasonably available information to scope the general areas across the company's own operations, subsidiaries, and relevant chains of activities where impacts are most likely and most severe. Then conduct an in-depth assessment in those areas and decide whether each identified impact is potential or actual. If the company cannot address all identified impacts at the same time and to their full extent, Article 9 requires prioritisation based on severity and likelihood.
The classification should also record involvement and influence. Articles 10 and 11 ask whether the company caused the impact, caused it jointly through acts or omissions with a subsidiary or business partner, or whether only a business partner caused it. They also distinguish where the impact occurs in the chain of activities and whether the company can influence the relevant business partner.
Articles 8 and 9 establish identification, assessment, and prioritisation of actual and potential adverse impacts.
Article 3(6) replaces Article 8(2) with reasonably-available-information scoping followed by in-depth assessment in the areas where impacts are most likely and most severe.
The Commission page summarises the core due diligence duty as identifying and addressing potential and actual adverse impacts in own operations, subsidiaries, and relevant business partners.
For , Article 10 lists that may be relevant depending on the circumstances. A prevention action plan is needed where the nature or complexity of the measures requires one, and it should include reasonable and clearly defined timelines plus qualitative and quantitative indicators for improvement.
Article 10 covers more than supplier clauses. It also points to investments, operational adjustments, purchasing-practice changes, design and distribution changes, targeted SME support, and collaboration where that increases the company's ability to prevent or mitigate the potential adverse impact.
Article 10 lists potential-impact prevention and mitigation measures, including prevention action plans, contractual assurances, investments, business changes, SME support, and collaboration.
Once the impact is actual, the response should be managed as Article 11 work. The first objective is to bring the impact to an end. If that cannot happen immediately, the company must minimise the extent of the impact, and Article 11 measures include neutralising the impact or minimising its extent, corrective action plans, contractual assurances, investments, operational changes, SME support, collaboration, and remediation where Article 12 applies.
A corrective action plan addresses a specific actual impact, while a prevention action plan addresses a potential impact. The corrective plan should use reasonable and clearly defined timelines and include qualitative and quantitative indicators for measuring improvement.
Article 11 sets the actual-impact response, and Article 12 addresses remediation where a company caused or jointly caused an actual adverse impact.
Directive (EU) 2026/470 removed mandatory termination and retained a mandatory last-resort response. If the preceding Article 10 or 11 measures fail, the company must refrain from new or extended relationships connected to the impact, adopt an enhanced action plan without undue delay where success can reasonably be expected, and suspend the affected activities where the governing law entitles it to do so.
Before suspension, the company must assess whether suspension could reasonably be expected to cause impacts that are manifestly more severe than the unresolved impact. If so, suspension is not required, and the company must be able to give the supervisory authority its duly justified reasons. A company that suspends must address the suspension's impacts, give reasonable notice, and keep the decision under review; a company that does not suspend must monitor the unresolved impact and periodically reassess the decision.
Article 3(8) and (9) replace Articles 10(6) and 11(7): they remove termination, require specified last-resort measures, condition suspension on governing law and a comparison of adverse impacts, and require notice, mitigation, monitoring, and review.
Use an impact file that lets a reviewer see the identified impact, the Article 10 or Article 11 classification, the prioritisation basis, stakeholder input, measures selected, implementation status, and monitoring result.
Article 15 requires effectiveness assessment. Directive (EU) 2026/470 uses a regular cycle of at least every five years plus event-driven reassessment after significant change or when reasonable grounds indicate new risks or ineffective measures.
Article 3(11) replaces Article 15 with monitoring after a significant change, at least every five years, and whenever reasonable grounds indicate new risks or ineffective measures.
This CSDDD FAQ helps separate potential-impact prevention, potential-impact mitigation, actual-impact corrective measures, stakeholder input, and monitoring evidence.
"should be clearly distinguished"
"manifestly more severe"
"preventing and mitigating potential problems, bringing actual ones to an end"
"identifying and addressing potential and actual adverse human rights and environmental impacts"