We use privacy-by-default, cookieless analytics.

Optional analytics cookies are used only if you accept them.

Read our Terms of Use and Privacy Policy.

CSDDD FAQTiming

Does CSDDD still have separate scope waves?

No. Directive (EU) 2026/470 replaced the earlier staggered schedule with one application date: 26 July 2029 for every company that remains in amended Article 2 scope.

Member States transpose by 26 July 2028; Article 16 measures apply for financial years starting on or after 1 January 2030.

Back to main artifactReview sources
Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Questions
2

Structured answer sets in this page tree.

Primary sources
2

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

No company tier applies before another under the current schedule. Older material may show 2027, 2028, and 2029 waves, or the two-wave schedule adopted in 2025. replaced those schedules with one application date for every company that remains in Article 2 scope.

Search this module

Find a question or answer quickly

2 of 2 questions
Question 1

Current answer and planning record

The current schedule has one company application date, but it still has distinct legal and reporting milestones. is due first, the due diligence measures apply next, and follows by reference to the start of a financial year. Do not collapse those events into one deadline.

A company can prepare before 2029 without describing the amended as already directly applicable to every control. Existing national due diligence laws, sector rules, contracts, and voluntary commitments may impose earlier or different duties and need their own source and date.

  • 26 July 2028: and supervisory-authority notification deadline.
  • 26 July 2029: application to all companies remaining within amended Article 2 scope.
  • 1 January 2030: measures apply for financial years starting on or after this date.
  • The single date does not put every former wave company back in scope. Recheck the amended Article 2 thresholds before assigning the 2029 application date.
  • Do not retain 'first wave' and 'broader wave' labels in a current-law calendar.
  • Keep old schedules only in a clearly marked legislative-history record, and track Commission guidance, national , reporting, and ESAP as separate milestones.
Citations
Question 2

What should replace a wave-based implementation plan?

Use an entity-by-entity scope record. An EU company passes the general route only when it has more than 5,000 employees on average and more than EUR 1.5 billion net worldwide turnover, or it is the ultimate parent of a group meeting both thresholds on a consolidated basis. A third-country company uses more than EUR 1.5 billion net turnover generated in the Union, with a corresponding consolidated ultimate-parent route and no employee threshold.

The separate franchise and licensing route requires more than EUR 75 million in qualifying Union royalties and more than EUR 275 million turnover. EU companies use net worldwide turnover from the last financial year; third-country companies use Union turnover from the financial year preceding the last financial year. Every applicable Article 2 route must be met in two consecutive financial years, and scope ends only after two consecutive relevant years below the conditions.

Once scope is established, record 26 July 2029 as the application date and work backward from national , Commission guidance, voluntary model contractual-clause guidance due by 26 July 2027, and reporting dependencies. A legacy wave label does not establish current scope or a current deadline.

  • Inputs: entity formation law, group and ultimate-parent structure, employee count where applicable, net-turnover basis, Union allocation, qualifying royalties, and the two relevant financial years.
  • Branches: EU general route, third-country general route, EU franchise or licensing route, third-country franchise or licensing route, or outside Article 2 on current evidence.
  • Evidence: adopted or consolidated financial statements, employee calculation, agreement and royalty schedule, control analysis, currency method, consolidation eliminations, reviewer approval, and unresolved assumptions.
  • Reassessment: repeat after a threshold-crossing year, acquisition, disposal, restructuring, restatement, change in ultimate parent, new qualifying agreement, or amended national measure.
Citations

Replace the old wave model

Use one current application date and keep guidance, reporting, and ESAP milestones as separate dependencies.

Research workflow
Open Research Copilot

Connect the CSDDD decision to cited sources, owners, evidence, and reviewable implementation work.

Explore next step
Next step
Open the amended CSDDD hub

Return to current scope, dates, due diligence, reporting, and enforcement guidance.

Explore next step
Talk to Sorena
Discuss CSDDD implementation

Review the relevant entity, national-law dependency, evidence gap, and next control decision with Sorena.

Explore next step
Primary sources

References and citations

Related guides

Explore more topics

CSDDD adverse impact prioritisation workflow
A CSDDD workflow for identifying actual and potential adverse human rights and environmental impacts, ranking severity and likelihood, and documenting prevention, mitigation, remediation, and stakeholder evidence.
CSDDD Applicability Test After 2026 Changes
Test CSDDD scope after Directive (EU) 2026/470 using the current EU and third-country thresholds, parent-company rules, exclusions, dates, and evidence.
CSDDD chain of activities and supplier due diligence
Explain CSDDD chain-of-activities scope, upstream and downstream boundaries, subsidiaries, direct and indirect business partners, supplier risk segmentation, and evidence.
CSDDD Chain of Activities Boundaries
Define CSDDD upstream and downstream chain of activities boundaries for subsidiaries, direct and indirect business partners, distribution, transport, storage, and records.
CSDDD chain of activities boundaries: upstream and downstream FAQ
FAQ on how the CSDDD defines chain of activities boundaries for subsidiaries, direct and indirect business partners, upstream activities, downstream logistics, and evidence.
CSDDD complaints and notifications FAQ
FAQ on Article 14 CSDDD complaint and notification mechanisms, who may complain, follow-up rights, confidentiality, retaliation, and evidence.
CSDDD compliance duties and evidence guide
A source-backed CSDDD compliance guide covering due diligence policy, impact scoping, prevention, corrective action, complaints, monitoring, reporting, climate-plan status, and supervisory evidence.
CSDDD contractual assurances FAQ for Articles 10 and 11
How CSDDD Articles 10 and 11 use contractual assurances with business partners, verification, SME support, action plans, and possible suspension escalation.
CSDDD Deadlines After Directive 2026/470
Current CSDDD calendar: 2027-2028 guidance, 2028 transposition, 2029 application, 2030 reporting, 2031 ESAP submission and review.
CSDDD due diligence checklist
A source-backed CSDDD checklist for scope, risk scoping, impact prioritisation, action plans, complaints, monitoring, communication, evidence, and the removed climate-plan duty.
CSDDD Due Diligence Steps Playbook for Articles 5 and 7-16
A playbook using current CSDDD provisions for policy integration, impact assessment, prioritisation, prevention, correction, remediation, stakeholder engagement, complaints, monitoring, communication, and evidence.
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.
CSDDD grievance and remediation workflow guide
Build a CSDDD grievance, notification, stakeholder engagement, and remediation workflow under Directive (EU) 2024/1760 as amended by Directive (EU) 2026/470.
CSDDD Liability and Enforcement After 2026
Understand CSDDD supervision, national penalties, substantiated concerns, remedial orders, and civil-liability analysis after Directive (EU) 2026/470.
CSDDD Non-EU Scope and 2029 Start
Test third-country CSDDD scope using the amended EUR 1.5 billion EU-turnover route and one 26 July 2029 application date.
CSDDD Penalties After Directive 2026/470
Current CSDDD penalty guidance after the EU 5% rule was replaced by a uniform 3% maximum limit: national sanctions, authority decisions, evidence, and country-by-country monitoring.
CSDDD prevention vs mitigation: potential and actual adverse impacts
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.
CSDDD remediation FAQ: when companies must remedy adverse impacts
FAQ on CSDDD remediation: when Article 12 requires remedy, how complaints and stakeholder engagement affect the response, and what evidence to keep.
CSDDD Remediation Plan Template: Article 12, 13 and 14 evidence
A CSDDD remediation plan template for actual adverse impacts, complaint inputs, stakeholder engagement, action records, and monitoring under the Directive as amended in 2026.
CSDDD requirements: scope, due diligence, climate plan, and evidence
A source-backed map of current CSDDD requirements across scope, due diligence policy, impact assessment, complaints, remediation, monitoring, communication, and the removed climate-plan duty.
CSDDD risk prioritisation FAQ: severity, likelihood, and evidence
How to prioritise CSDDD adverse impacts when teams cannot address everything at once, using severity, likelihood, stakeholder evidence, and a reviewable rationale.
CSDDD Scope Thresholds After 2026
Understand amended CSDDD thresholds for EU and non-EU companies, group scope, exclusions, two-year evidence, and the 2029 application date.
CSDDD Supplier Contract Clause Review Workflow
Review supplier contract clauses against CSDDD Articles 10 and 11: contractual assurances, verification, SME fairness, support, action plans, and escalation evidence.
CSDDD Supplier Contract Clauses: Articles 10 and 11 Evidence
How to use CSDDD supplier contract clauses without treating clauses as a substitute for due diligence: contractual assurances, verification, SME support, action plans, limits, and evidence.
CSDDD supplier human rights impact scoring template
A CSDDD supplier impact scoring template for Article 8 identification, Article 9 prioritisation, severity, likelihood, stakeholder input, chain-of-activities boundaries, and evidence records.
CSDDD vs CSRD: Due Diligence and Reporting Compared
Compare CSDDD due diligence duties with CSRD sustainability reporting, including scope, timing, Article 16 reporting, evidence overlap, assurance, and enforcement.
CSDDD vs German LkSG Comparison
Compare the EU CSDDD with Germany's LkSG without mixing directive duties, national-law duties, chain boundaries, complaints, reporting, and enforcement routes.
CSDDD vs OECD Guidelines
Compare the binding EU CSDDD with the OECD Guidelines for responsible business conduct across scope, due diligence duties, business relationships, remediation, and evidence.
Did CSDDD Keep Its Climate Plan Duty?
Directive (EU) 2026/470 removed the standalone CSDDD Article 22 climate-transition-plan duty. Understand what changed and which separate obligations may remain.
Does Franchising Trigger CSDDD Scope?
Directive (EU) 2026/470 retained the CSDDD franchise and licensing scope route but raised its royalty and turnover thresholds. Learn the current test.
How CSDDD overlaps with OECD, UNGP, and ILO standards
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.
How Does CSDDD Civil Liability Work Now?
Directive (EU) 2026/470 removed the uniform EU liability test but retained compensation and procedural safeguards. Claims still depend on Member State law.
Is a Climate Plan Still Required by CSDDD?
Directive (EU) 2026/470 removed the standalone CSDDD Article 22 climate-transition-plan duty; separate CSRD and national obligations need their own review.
What Did Omnibus Change in CSDDD?
CSDDD Omnibus status as of July 2026: what Directives (EU) 2025/794 and 2026/470 adopted, which dates apply, and which old duties were removed.
What EU Turnover Triggers CSDDD Scope?
A third-country company generally needs more than EUR 1.5 billion net turnover in the EU under Directive (EU) 2026/470; learn the evidence and timing.