--- title: "CSDDD scope waves: current Article 37 dates and thresholds" canonical_url: "https://www.sorena.io/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/scope-waves" source_url: "https://www.sorena.io/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/scope-waves" author: "Sorena AI" description: "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." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "CSDDD scope waves" - "Directive (EU) 2025/794" - "Article 37" - "CSDDD thresholds" - "CSDDD" - "Directive (EU) 2024/1760" - "scope thresholds" - "application dates" - "corporate sustainability due diligence" --- **[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 scope waves: current Article 37 dates and thresholds 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. *FAQ* *CSDDD* *EU* ## CSDDD scope waves current dates and thresholds Directive (EU) 2025/794 changed Article 37 of the CSDDD. The current application waves start on 26 July 2028 and 26 July 2029, not 26 July 2027. Use this FAQ to separate Article 2 scope, Article 37 application timing, and Article 16 communication timing. CSDDD scope waves are the phase-in rules that decide when an in-scope company must apply national measures transposing Directive (EU) 2024/1760. The current Article 37 text, as amended by Directive (EU) 2025/794, gives Member States until 26 July 2027 to transpose the directive and applies the due diligence measures in two main waves: 26 July 2028 for the larger EUR 900 million cohorts and 26 July 2029 for the remaining Article 2 in-scope companies. ## What are the current CSDDD scope waves after Directive (EU) 2025/794? 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. - 26 July 2027: Member States' transposition deadline under the amended Article 37 text. - 26 July 2028: first application wave for the larger EU and third-country Article 2(1)(a)-(b) and Article 2(2)(a)-(b) cohorts above the EUR 900 million threshold. - 26 July 2029: application for all other companies in Article 2(1)(a)-(b), Article 2(2)(a)-(b), and the franchise or licensing categories in Article 2(1)(c) and Article 2(2)(c). - Article 16 communication duties are delayed separately: financial years starting on or after 1 January 2029 for the 2028 wave, and financial years starting on or after 1 January 2030 for the 2029 wave. Sources for this answer: - [Directive (EU) 2025/794 amending CSDDD application dates](https://eur-lex.europa.eu/eli/dir/2025/794/oj/eng?ref=sorena.io) - Supports the current Article 37 transposition deadline and the amended 26 July 2028 and 26 July 2029 application waves. - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Provides the underlying CSDDD Article 2 company categories referenced by the amended Article 37 phase-in. ## Which companies move into the 26 July 2029 CSDDD wave? 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. - EU company threshold: more than 1,000 employees on average and more than EUR 450 million net worldwide turnover. - Third-country company threshold: more than EUR 450 million net turnover generated in the Union. - EU and non-EU parent groups can be in scope when the group reaches the relevant Article 2 threshold on a consolidated basis. - Franchise or licensing categories can be in scope even when the main employee-and-turnover test is not met. 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) - Supports the Article 2 EU, third-country, group, franchise, and licensing scope thresholds. - [Directive (EU) 2025/794 amending CSDDD application dates](https://eur-lex.europa.eu/eli/dir/2025/794/oj/eng?ref=sorena.io) - Supports that all other Article 2 in-scope companies move to the 26 July 2029 application date, with Article 16 from financial years starting on or after 1 January 2030. ## How should a company check its CSDDD wave? 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. - Classify the entity: EU company, EU ultimate parent group, third-country company, third-country ultimate parent group, or franchise/licensing category. - Measure the relevant Article 2 threshold using the financial year specified for that category. - Check whether the company reaches the larger 26 July 2028 wave: EU Article 2(1)(a)-(b) companies need more than 3,000 employees and more than EUR 900 million net worldwide turnover; third-country Article 2(2)(a)-(b) companies need more than EUR 900 million net turnover in the Union. - If the company is in Article 2 scope but not in the 2028 wave, treat 26 July 2029 as the application date for the due diligence measures. Sources for this answer: - [Directive (EU) 2025/794 amending CSDDD application dates](https://eur-lex.europa.eu/eli/dir/2025/794/oj/eng?ref=sorena.io) - Supports the operational distinction between the 2028 larger-company wave and the 2029 remaining in-scope-company wave. - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Supports the separate Article 2 scope tests for EU companies, third-country companies, groups, and franchise or licensing arrangements. ## What evidence should teams retain for CSDDD scope waves? 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. - Article 2 scope memo identifying the tested entity, group relationship, EU or third-country status, financial year, employee count where relevant, net turnover measure, and franchise or licensing royalty amount where relevant. - Article 37 wave conclusion naming 26 July 2028 or 26 July 2029 and explaining why the company is or is not in the larger EUR 900 million wave. - Article 16 note showing whether communication duties start for financial years beginning on or after 1 January 2029 or 1 January 2030. - Source extracts from Directive (EU) 2024/1760 and Directive (EU) 2025/794, with the date when the legal team last checked the current consolidated text. - Owner and review trigger list for annual financial statement adoption, group restructuring, EU turnover changes, and material changes to franchise or licensing arrangements. 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) - Supports the evidence fields tied to Article 2 thresholds and company categories. - [Directive (EU) 2025/794 amending CSDDD application dates](https://eur-lex.europa.eu/eli/dir/2025/794/oj/eng?ref=sorena.io) - Supports retaining the amended Article 37 application-date conclusion and Article 16 financial-year timing. ## What mistake should teams avoid with CSDDD scope waves? 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. - Do not describe the 2025 changes as only proposal-stage when relying on Directive (EU) 2025/794 for current Article 37 timing. - Do not apply the EU employee threshold to the main third-country company test in Article 2(2)(a). - Do not treat Article 16 communication dates as identical to the due diligence measure application dates. - Do not cite old phase-in dates without marking them as superseded by the amended Article 37 text. Sources for this answer: - [Directive (EU) 2025/794 amending CSDDD application dates](https://eur-lex.europa.eu/eli/dir/2025/794/oj/eng?ref=sorena.io) - Supports treating the amended Article 37 timing as current rather than proposal-stage. - [European Commission stop-the-clock proposal for CSRD and CSDDD dates](https://commission.europa.eu/document/download/0affa9a8-2ac5-46a9-98f8-19205bf61eb5_en?filename=COM_2025_80_EN.pdf&ref=sorena.io) - Provides background on the proposal that led to postponing the CSDDD transposition deadline and first application wave; use the adopted directive for the current rule. ## Primary sources - [Directive (EU) 2024/1760 on corporate sustainability due diligence](https://eur-lex.europa.eu/eli/dir/2024/1760/oj?ref=sorena.io) - Primary CSDDD text for Article 2 scope categories, thresholds, group treatment, franchise and licensing scope, and Article 16 communication duty. - Quote: "This Directive shall apply to companies" - [Directive (EU) 2025/794 amending CSDDD application dates](https://eur-lex.europa.eu/eli/dir/2025/794/oj/eng?ref=sorena.io) - Adopted amendment replacing the Article 37 transposition and application-date text used for current CSDDD scope-wave planning. - Quote: "the first and second subparagraphs are replaced" - [European Commission stop-the-clock proposal for CSRD and CSDDD dates](https://commission.europa.eu/document/download/0affa9a8-2ac5-46a9-98f8-19205bf61eb5_en?filename=COM_2025_80_EN.pdf&ref=sorena.io) - Background source for the legislative change that postponed the CSDDD transposition deadline and first application wave; not used as the current legal rule where Directive (EU) 2025/794 now applies. - Quote: "postpone the transposition deadline as well as the application of the Directive by 1 year" ## Topic Guides - [CSDDD adverse impact prioritisation workflow](/artifacts/eu/corporate-sustainability-due-diligence-directive/adverse-impact-prioritisation-workflow.md): 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: EU and Non-EU Company Scope](/artifacts/eu/corporate-sustainability-due-diligence-directive/applicability-test.md): Test whether Directive (EU) 2024/1760 may apply to an EU or non-EU company using grounded CSDDD employee, turnover, group, franchise, royalty, exclusion, and phase-in checks. - [CSDDD chain of activities and supplier due diligence](/artifacts/eu/corporate-sustainability-due-diligence-directive/chain-of-activities-and-suppliers.md): 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](/artifacts/eu/corporate-sustainability-due-diligence-directive/chain-of-activities-boundaries.md): 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](/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. - [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. - [CSDDD Climate Transition Plan Requirements](/artifacts/eu/corporate-sustainability-due-diligence-directive/climate-transition-plan.md): Article 22 CSDDD guidance for climate transition plans: business model alignment, targets, actions, funding, governance, and 12-month progress updates. - [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. - [CSDDD compliance duties and evidence guide](/artifacts/eu/corporate-sustainability-due-diligence-directive/compliance.md): A grounded CSDDD compliance guide covering due diligence policy, adverse impact identification, prevention, corrective action, complaints, monitoring, reporting, climate plans, and supervisory evidence. - [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. - [CSDDD deadlines and compliance calendar after Directive (EU) 2025/794](/artifacts/eu/corporate-sustainability-due-diligence-directive/deadlines-and-compliance-calendar.md): Current CSDDD calendar for transposition, application phases, Article 16 reporting exceptions, Commission guidance dates, and practical compliance evidence. - [CSDDD due diligence checklist](/artifacts/eu/corporate-sustainability-due-diligence-directive/checklist.md): A grounded CSDDD checklist for scope, due diligence policy, chain-of-activities risk mapping, impact prioritisation, action plans, complaints, monitoring, communication, climate planning, and evidence. - [CSDDD Due Diligence Steps Playbook for Articles 5 and 7-16](/artifacts/eu/corporate-sustainability-due-diligence-directive/due-diligence-steps-playbook.md): A grounded playbook for the CSDDD due diligence sequence: policy integration, impact assessment, prioritisation, prevention, correction, remediation, stakeholder engagement, complaints, monitoring, communication, and evidence. - [CSDDD FAQ: scope, dates, duties, liability, and evidence](/artifacts/eu/corporate-sustainability-due-diligence-directive/faq.md): Practical answers on CSDDD scope, current application dates, chain of activities, due diligence duties, complaints, remediation, civil liability, climate plans, and evidence. - [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. - [CSDDD grievance and remediation workflow guide](/artifacts/eu/corporate-sustainability-due-diligence-directive/grievance-and-remediation-workflows.md): Build a CSDDD grievance, notification, stakeholder engagement, and remediation workflow around Articles 12, 13, and 14 of Directive (EU) 2024/1760. - [CSDDD Liability and Penalties: enforcement, fines, and civil claims](/artifacts/eu/corporate-sustainability-due-diligence-directive/liability-and-penalties.md): A grounded guide to CSDDD supervisory enforcement, penalty mechanics, civil liability, compensation limits, evidence records, and national transposition caveats. - [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. - [CSDDD Non-EU Turnover Thresholds and Scope Waves](/artifacts/eu/corporate-sustainability-due-diligence-directive/scope-waves-and-non-eu-turnover.md): Article 2 and Article 37 CSDDD scope guide for non-EU Union turnover, group routes, franchise and licensing routes, and current application dates after Directive (EU) 2025/794. - [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. - [CSDDD penalties and fines under Article 27](/artifacts/eu/corporate-sustainability-due-diligence-directive/penalties-and-fines.md): How CSDDD Article 27 sets penalty rules, turnover-based fine caps, public decision publication, supervisory authority powers, and national transposition caveats. - [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. - [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. - [CSDDD Remediation Plan Template: Article 12, 13 and 14 evidence](/artifacts/eu/corporate-sustainability-due-diligence-directive/remediation-plan-template.md): A CSDDD remediation plan template for actual adverse impacts, complaint inputs, stakeholder engagement, action records, and monitoring evidence. - [CSDDD requirements: scope, due diligence, climate plan, and evidence](/artifacts/eu/corporate-sustainability-due-diligence-directive/requirements.md): A grounded map of the Corporate Sustainability Due Diligence Directive requirements across scope, due diligence policy, impact assessment, complaints, remediation, monitoring, communication, and climate transition planning. - [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. - [CSDDD Scope Thresholds: EU, Non-EU, Group and Franchise Routes](/artifacts/eu/corporate-sustainability-due-diligence-directive/scope-thresholds-and-in-scope-groups.md): Article 2 CSDDD scope thresholds for EU companies, non-EU Union turnover, ultimate-parent groups, franchise and licensing routes, consecutive-year tests, and evidence records. - [CSDDD Supplier Contract Clause Review Workflow](/artifacts/eu/corporate-sustainability-due-diligence-directive/supplier-contract-clause-review-workflow.md): 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](/artifacts/eu/corporate-sustainability-due-diligence-directive/supplier-contract-clauses.md): 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](/artifacts/eu/corporate-sustainability-due-diligence-directive/supplier-human-rights-risk-scoring-template.md): 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 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. - [CSDDD vs CSRD: Due Diligence and Reporting Compared](/artifacts/eu/corporate-sustainability-due-diligence-directive/csddd-vs-csrd.md): 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](/artifacts/eu/corporate-sustainability-due-diligence-directive/csddd-vs-german-lksg.md): 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](/artifacts/eu/corporate-sustainability-due-diligence-directive/csddd-vs-oecd-guidelines.md): Compare the binding EU CSDDD with the OECD Guidelines for responsible business conduct across scope, due diligence duties, business relationships, remediation, and evidence. - [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. *Recommended next step* *Placement: after evidence section* ## Check your CSDDD application wave Turn Article 2 thresholds and the amended Article 37 dates into a documented scope conclusion before updating CSDDD calendars, supplier requests, or governance plans. - [Open Research Copilot](/solutions/research-copilot.md): Check CSDDD scope questions against cited EU source material. - [Discuss CSDDD implementation](/contact.md): Review CSDDD scope, application dates, and evidence records 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). All rights reserved. Source: https://www.sorena.io/artifacts/eu/corporate-sustainability-due-diligence-directive/faq/scope-waves