CSDDD scope waves current dates and thresholds

The current CSDDD phase-in is no longer the original 26 July 2027, 26 July 2028, and 26 July 2029 sequence. Directive (EU) 2025/794 amended Article 37 so Member States must transpose by 26 July 2027 and apply the national measures from 26 July 2028 for the larger wave and from 26 July 2029 for all other in-scope companies.

For the 26 July 2028 wave, Article 37 covers EU companies and EU-parent groups in Article 2(1), points (a) and (b), that had more than 3,000 employees on average and more than EUR 900 million net worldwide turnover in the relevant financial year. It also covers third-country companies and groups in Article 2(2), points (a) and (b), that generated more than EUR 900 million net turnover in the Union.

The 26 July 2029 wave is the catch-up wave for companies that are in Article 2 scope but are not in the larger 26 July 2028 EUR 900 million cohorts. For EU companies, the main Article 2(1)(a) threshold remains more than 1,000 employees on average and more than EUR 450 million net worldwide turnover. Ultimate parent companies of groups meeting those thresholds are also covered.

The 2029 wave also includes the CSDDD franchise and licensing categories. For EU companies or groups, Article 2(1)(c) uses royalties above EUR 22.5 million and net worldwide turnover above EUR 80 million where the arrangements involve a common identity, business concept, and uniform business methods. For third-country companies or groups, Article 2(2)(c) uses the same royalty amount in the Union and an EU net turnover threshold above EUR 80 million.

Start with Article 2 scope, then apply Article 37 timing. A company outside Article 2 is not pulled in merely because a business partner asks for CSDDD information. A company inside Article 2 still needs the amended Article 37 test to identify whether its first application date is 26 July 2028 or 26 July 2029.

Keep the EU and third-country tests separate. EU companies use employee and net worldwide turnover thresholds. Third-country companies use net turnover generated in the Union, and no employee threshold is listed for the main Article 2(2)(a) test.

Retain evidence that lets a reviewer reconstruct both parts of the analysis: why the company is or is not within Article 2, and why the selected application date follows from the amended Article 37 text. The record should not rely on the superseded 26 July 2027 first-wave date from the original directive text.

The evidence file should be refreshed when consolidated group numbers, EU turnover, franchise or licensing royalties, or national transposition rules change.

The main mistake is using the original Directive (EU) 2024/1760 phase-in schedule as if it were still current. That can incorrectly leave a 26 July 2027 first wave in calendars and supplier requests. Current planning should use the Article 37 wording amended by Directive (EU) 2025/794.

A second mistake is blending CSDDD scope with CSRD reporting waves or supplier due diligence requests. CSDDD scope waves are based on Article 2 CSDDD categories and Article 37 CSDDD application dates. A smaller supplier may still receive information requests from an in-scope customer, but that is not the same as being directly in CSDDD scope.