CSDDD FAQRemoved duty

Is a climate transition plan still required by CSDDD?

No standalone Article 22 duty remains after Directive (EU) 2026/470.

That answer is limited to . Test CSRD, national, sector, contractual, financing, and public-commitment requirements separately.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

No standalone climate-transition-plan duty remains in the amended . Directive (EU) 2026/470 deleted Article 22 before the amended due diligence rules are due to apply through national law on 26 July 2029. Older material describing the original Article 22 is historical. This does not remove separate climate planning or disclosure duties under other EU law, national law, sector rules, contracts, financing terms, or public commitments.

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3 of 3 questions
Question 1

What changed, and when?

The original Directive (EU) 2024/1760 required certain in-scope companies to adopt and put into effect a for climate-change mitigation. The plan was to pursue, through best efforts, compatibility with a sustainable economy, the Paris Agreement 1.5 C limit, and EU climate neutrality, including intermediate and 2050 targets.

Historical Article 22 required time-bound 2030 targets and five-year steps to 2050, appropriate Scope 1, Scope 2, and Scope 3 absolute emissions-reduction targets, decarbonisation levers and key actions, quantified investment and funding, and the role of administrative, management, and supervisory bodies. It also required an update every 12 months with progress against targets. Directive (EU) 2026/470 entered into force on 18 March 2026 and states that Article 22 is deleted.

Member States must transpose the -related 2026 amendments by 26 July 2028 and apply them from 26 July 2029. The amended CSDDD does not require Member States to impose the former standalone Article 22 duty. A national law may still contain a climate-plan obligation on another basis, including an earlier or separate national measure, so the company must check the law that applies to it.

  • Current amended text: Article 22 is deleted.
  • Amendment in force: 18 March 2026.
  • amendment transposition deadline: 26 July 2028.
  • Application of amended due diligence rules through national law: 26 July 2029.
  • Separate national, sector, reporting, contractual, financing, and public-commitment duties remain outside this answer.
Question 2

Could another rule still require a transition plan or climate disclosure?

Yes. Deleting Article 22 answers only the CSDDD question. A company may still need a plan, plan disclosure, targets, or progress reporting under the Corporate Sustainability Reporting Directive and applicable European Sustainability Reporting Standards, national climate or corporate law, sector regulation, lending or investment terms, procurement conditions, or a public commitment.

Keep the legal tests separate. is a disclosure requirement concerning a transition plan for climate-change mitigation; it does not recreate the former duty for every company. Whether ESRS E1-1 applies depends on the reporting entity's current CSRD scope, the applicable reporting period and standards, and its materiality assessment. A contractual or voluntary plan may also use different boundaries, targets, governance, and assurance.

  • Confirm the entity and group perimeter for each possible obligation.
  • Identify whether the requirement is to adopt a plan, implement it, disclose it, update it, assure it, or report progress.
  • Check the applicable date, materiality test, climate boundary, target period, and governing law.
  • Do not cite former Article 22 as the basis for a control that now rests on another instrument.
Question 3

What should a company do with an existing CSDDD Article 22 control?

Do not delete the plan or its evidence merely because Article 22 was removed. First identify every remaining basis for the control. Then relabel the owner, evidence, update cycle, and assurance statement so each one points to the rule, contract, or commitment that still requires it.

If no other basis remains, record the legal change and retire the -specific obligation in a controlled way. Preserve historical decisions and public statements that still need an audit trail, and correct any current statement that says the amended CSDDD itself requires the plan.

  • Record Directive (EU) 2026/470 as the source removing the standalone duty.
  • Remove the current-law claim that the itself requires adoption, implementation, and a 12-month update.
  • Map each retained climate control to its remaining legal, contractual, risk, or voluntary basis.
  • Update obligation registers, training, board papers, public claims, and assurance scopes.
  • Keep the original Article 22 record only as historical context, not as the current legal basis.
  • Do not infer that all climate planning or reporting duties disappeared.
Primary sources

References and citations

eur-lex.europa.eu4 citations
Referenced sections
  • Current status source for deletion of Article 22, entry into force, transposition, and application dates.
  • Article 4(16) deletes CSDDD Article 22; Articles 5 and 6 establish the amendment's transposition, application, and entry-into-force dates.
  • Current amendment to both the CSRD framework and the CSDDD; scope and timing must be assessed under the relevant amended instrument.
Show 1 more
  • Binding amendment deleting the standalone CSDDD Article 22 duty and setting the amended CSDDD timetable.
"Article 22 is deleted"
eur-lex.europa.eu3 citations
Referenced sections
  • Historical source for the former CSDDD climate-transition-plan duty.
  • Historical Article 22 source for the former adoption, implementation, plan-content, and update requirements.
  • Historical source for the former Article 22 plan, implementation, content, and annual-update provisions.
"adopt and put into effect a transition plan"
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