Directive (EU) 2026/470 changed the penalty and civil-liability framework. The old EU 5% rule was replaced by a uniform 3% maximum limit, and the original harmonised Article 29 liability formula no longer applies.
The practical analysis now requires the amended Directive plus the transposition law, authority, procedure, sanction rules, and civil-liability law of each relevant Member State.
Structured answer sets in this page tree.
Cited legal and guidance references.
CSDDD requires Member States to provide supervision, orders, penalties, and access to review, but it does not impose a self-executing EU fine on a company. Administrative enforcement and civil liability are separate tracks. A is the Article 26 route for asking a supervisory authority to examine suspected non-compliance based on objective circumstances. Apply the amended Directive through the transposition law, competent authority, procedure, and private law of the relevant Member State.
National supervisory authorities must be able to request information and investigate compliance with Articles 7 to 16. They may investigate on their own initiative or after receiving a based on objective circumstances. If they find non-compliance, they must have powers that include ordering an infringement to cease, preventing repetition, ordering proportionate remediation where appropriate, imposing penalties, and adopting interim measures where severe and irreparable harm is imminent.
Member States must transpose the amended CSDDD by 26 July 2028 and apply those national measures from 26 July 2029, except that Article 16 reporting measures apply for financial years starting on or after 1 January 2030. Before those dates, track each transposition law and authority designation; do not present the Directive alone as an already-operative national penalty or damages rule.
The original Directive required national maximum fine limits of at least 5% of net worldwide turnover. Directive (EU) 2026/470 replaced that rule. Member States must now set the maximum limit at 3% of the company's net worldwide turnover in the financial year before the fine decision or, for the ultimate-parent cases named in amended Article 27(4), 3% of net consolidated worldwide turnover at ultimate-parent level.
Directive (EU) 2026/470 deleted the original EU liability test in Article 29(1). Whether a claimant has a cause of action, who may bring it, fault, causation, protected damage, limitation, evidence, costs, and available remedies must therefore be tested under the relevant national law. If a company is held liable under national law for damage caused to a natural or legal person by failure to comply with CSDDD due diligence requirements, Article 29(2) still requires full compensation without punitive, multiple, or other overcompensation.
Connect each entity to its authority, transposition law, response evidence, penalty rules, and civil-liability analysis.
Connect the CSDDD decision to cited sources, owners, evidence, and reviewable implementation work.
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