CSRD and both concern corporate sustainability, but they create different duties. CSRD requires covered undertakings to disclose sustainability information in a management-report sustainability statement prepared under ESRS and subject to assurance. CSDDD requires in-scope companies to carry out risk-based human rights and environmental due diligence in their own operations, subsidiaries, and . Directive (EU) 2026/470 narrowed both regimes, set CSDDD application from 26 July 2029, and deleted CSDDD Article 22, so CSDDD no longer contains a standalone climate-transition-plan duty.
Comparison matrix
CSRD vs CSDDD: the operational difference
CSRD governs reported sustainability information. governs the due diligence process used to identify and address adverse human rights and environmental impacts. Similar source data may support both, but a disclosure does not prove that the company performed the required due diligence.
Corporate Sustainability Reporting Directive: sustainability information in the management report, prepared under ESRS and linked to assurance and digital reporting.
Second framework
CSDDD
Corporate Sustainability Due Diligence Directive: risk-based due diligence for adverse human rights and environmental impacts. Directive (EU) 2026/470 removed the former standalone Article 22 climate-transition-plan duty.
The original CSRD scope used Accounting Directive company categories. Directive (EU) 2026/470 narrows the main Articles 19a and 29a scope from financial years beginning in 2027 to undertakings and parent groups exceeding EUR 450 million net turnover and 1,000 average employees, with separate exemption, sector, issuer, national, and third-country analysis.
After Directive (EU) 2026/470, the general route covers an EU company above 5,000 average employees and EUR 1.5 billion net worldwide turnover, or a third-country company above EUR 1.5 billion net turnover in the Union. Separate franchising or licensing routes apply where royalties from qualifying agreements in the Union exceed EUR 75 million and turnover exceeds EUR 275 million, measured worldwide for an EU company or group and in the Union for a third-country company or group. Relevant ultimate-parent routes remain, and scope is tested over the consecutive financial years specified in Article 2.
Run two scope memos. A company can be in CSRD but outside , in CSDDD but using CSRD reporting to satisfy part of CSDDD communication, or in both with different legal triggers.
Supports the amended CSDDD Article 2 thresholds, ultimate-parent routes, consecutive-financial-year test, and removal of the former Article 22 climate-transition-plan duty.
CSRD is about public sustainability reporting. It amends the Accounting Directive so covered undertakings report sustainability information needed to understand their impacts and how sustainability matters affect them.
is about company conduct. It requires in-scope companies to run risk-based human rights and environmental due diligence across their own operations, subsidiaries, and chains of activities.
Do not treat a CSRD disclosure as proof that due diligence has been performed. A report can describe due diligence, but CSDDD asks whether the underlying due diligence actions happened.
CSRD work is a reporting workstream: assessment, ESRS disclosure mapping, value chain information, policies, actions, metrics, targets, narrative controls, management-report integration, assurance preparation, and digital tagging readiness.
work is a due diligence workstream: integrate due diligence into policies and risk management, identify and assess adverse impacts, prioritise where needed, prevent or mitigate potential impacts, end or minimise actual impacts, remediate, engage stakeholders, maintain complaints and notification channels, monitor, and communicate.
The same sustainability team may support both regimes, but the deliverables differ: CSRD produces an assured sustainability statement; produces operating controls and evidence that adverse impacts were addressed.
CSRD uses under ESRS: impact materiality and financial materiality are considered in their own right, and material impacts, risks, and opportunities drive what is disclosed.
uses adverse-impact due diligence: companies assess actual and potential adverse human rights and environmental impacts and, where not all impacts can be addressed at once, prioritise by severity and likelihood.
A CSRD assessment can inform risk identification, but it should not replace the CSDDD adverse-impact analysis, prioritisation, prevention, corrective action, remediation, and monitoring records.
CSRD evidence should support reported ESRS disclosures: materiality method and approvals, data-point inventory, source systems, estimates and value chain limitations, policies and actions, metrics and targets, consolidation decisions, management-report text, assurance requests, and digital-tagging decisions.
evidence should support conduct: due diligence policy, adverse-impact assessments, prioritisation rationale, prevention and corrective action plans, contractual assurances and verification, SME support, stakeholder engagement, complaints handling, remediation, monitoring results, and annual statements. Do not retain the former standalone Article 22 climate-plan workstream as a current CSDDD obligation.
Reuse underlying supplier or impact evidence only when the fact, perimeter, owner, time period, and source requirement match. Otherwise keep the CSRD reporting file and due diligence file separate.
For financial years starting on or after 1 January 2027, the amended CSRD scope applies to undertakings and parent groups exceeding both EUR 450 million net turnover and 1,000 average employees. Member States may exempt undertakings below either threshold for financial years beginning in 2025 or 2026, so national transposition still matters for those two years.
Member States must adopt the amended rules by 26 July 2028 and apply them from 26 July 2029. The Article 16 annual communication rules apply for financial years starting on or after 1 January 2030. The earlier phased dates in Directive (EU) 2024/1760 no longer control.
Record the applicable financial year, entity or group thresholds, and national implementing law for each regime. Do not carry the original CSRD waves or phase-in dates into the workplan.
CSRD is tied to assurance of sustainability reporting. The audit framework includes assurance files and reports, independence, quality assurance, investigations, and sanctions through Member State implementation.
is supervised by national authorities with information-gathering, investigation, order, and penalty powers. Directive (EU) 2026/470 requires Member States to set the maximum pecuniary-penalty limit at 3% of net worldwide turnover. It deleted the harmonised civil-liability rule in Article 29(1); compensation now depends on liability under national law, subject to the remaining Article 29 safeguards.
Prepare CSRD information for assurance and conduct for supervisory review. Assess civil exposure under the relevant national law rather than describing CSDDD as a uniform EU damages cause of action.
CSRD disclosures can include due diligence policies, adverse-impact information, value chain impacts, climate transition plans, and sustainability targets where material under ESRS.
Article 16 says the annual CSDDD statement requirement does not apply to companies already subject to sustainability reporting under Articles 19a, 29a, or 40a of the Accounting Directive, including certain exempted companies.
The strongest integration point is communication, not scope. CSRD reporting may satisfy the annual-statement channel for covered reporters, but it does not remove the CSDDD duty to perform due diligence.
ESRS value chain information can cover activities, resources, and relationships from conception to delivery, consumption, and end of life, including upstream and downstream actors where material.
uses the defined concept of . It covers upstream business-partner activities related to production or service provision and specified downstream distribution, transport, and storage activities carried out for or on behalf of the company.
Do not assume the two perimeter terms are identical. Keep a crosswalk showing which suppliers, distributors, logistics partners, products, services, and geographies are covered by each regime.
Supports the CSDDD chain-of-activities definition in Article 3.
Scope boundary
CSRD
The original CSRD scope used Accounting Directive company categories. Directive (EU) 2026/470 narrows the main Articles 19a and 29a scope from financial years beginning in 2027 to undertakings and parent groups exceeding EUR 450 million net turnover and 1,000 average employees, with separate exemption, sector, issuer, national, and third-country analysis.
CSDDD
After Directive (EU) 2026/470, the general route covers an EU company above 5,000 average employees and EUR 1.5 billion net worldwide turnover, or a third-country company above EUR 1.5 billion net turnover in the Union. Separate franchising or licensing routes apply where royalties from qualifying agreements in the Union exceed EUR 75 million and turnover exceeds EUR 275 million, measured worldwide for an EU company or group and in the Union for a third-country company or group. Relevant ultimate-parent routes remain, and scope is tested over the consecutive financial years specified in Article 2.
Operational implication
Run two scope memos. A company can be in CSRD but outside , in CSDDD but using CSRD reporting to satisfy part of CSDDD communication, or in both with different legal triggers.
Supports the amended CSDDD Article 2 thresholds, ultimate-parent routes, consecutive-financial-year test, and removal of the former Article 22 climate-transition-plan duty.
Purpose of the framework
CSRD
CSRD is about public sustainability reporting. It amends the Accounting Directive so covered undertakings report sustainability information needed to understand their impacts and how sustainability matters affect them.
CSDDD
is about company conduct. It requires in-scope companies to run risk-based human rights and environmental due diligence across their own operations, subsidiaries, and chains of activities.
Operational implication
Do not treat a CSRD disclosure as proof that due diligence has been performed. A report can describe due diligence, but CSDDD asks whether the underlying due diligence actions happened.
Supports the CSDDD side: Article 5 lists the due diligence actions companies must carry out.
Required workstreams
CSRD
CSRD work is a reporting workstream: assessment, ESRS disclosure mapping, value chain information, policies, actions, metrics, targets, narrative controls, management-report integration, assurance preparation, and digital tagging readiness.
CSDDD
work is a due diligence workstream: integrate due diligence into policies and risk management, identify and assess adverse impacts, prioritise where needed, prevent or mitigate potential impacts, end or minimise actual impacts, remediate, engage stakeholders, maintain complaints and notification channels, monitor, and communicate.
Operational implication
The same sustainability team may support both regimes, but the deliverables differ: CSRD produces an assured sustainability statement; produces operating controls and evidence that adverse impacts were addressed.
Supports the CSDDD due diligence side through Articles 5 and 7 to 16.
Core obligations
CSRD
CSRD uses under ESRS: impact materiality and financial materiality are considered in their own right, and material impacts, risks, and opportunities drive what is disclosed.
CSDDD
uses adverse-impact due diligence: companies assess actual and potential adverse human rights and environmental impacts and, where not all impacts can be addressed at once, prioritise by severity and likelihood.
Operational implication
A CSRD assessment can inform risk identification, but it should not replace the CSDDD adverse-impact analysis, prioritisation, prevention, corrective action, remediation, and monitoring records.
Supports the CSDDD adverse-impact and prioritisation logic in Articles 8 and 9.
Evidence record
CSRD
CSRD evidence should support reported ESRS disclosures: materiality method and approvals, data-point inventory, source systems, estimates and value chain limitations, policies and actions, metrics and targets, consolidation decisions, management-report text, assurance requests, and digital-tagging decisions.
CSDDD
evidence should support conduct: due diligence policy, adverse-impact assessments, prioritisation rationale, prevention and corrective action plans, contractual assurances and verification, SME support, stakeholder engagement, complaints handling, remediation, monitoring results, and annual statements. Do not retain the former standalone Article 22 climate-plan workstream as a current CSDDD obligation.
Operational implication
Reuse underlying supplier or impact evidence only when the fact, perimeter, owner, time period, and source requirement match. Otherwise keep the CSRD reporting file and due diligence file separate.
Supports the original CSDDD evidence architecture; Directive (EU) 2026/470 must be applied for the current duties and removal of former Article 22.
Timing and deadlines
CSRD
For financial years starting on or after 1 January 2027, the amended CSRD scope applies to undertakings and parent groups exceeding both EUR 450 million net turnover and 1,000 average employees. Member States may exempt undertakings below either threshold for financial years beginning in 2025 or 2026, so national transposition still matters for those two years.
CSDDD
Member States must adopt the amended rules by 26 July 2028 and apply them from 26 July 2029. The Article 16 annual communication rules apply for financial years starting on or after 1 January 2030. The earlier phased dates in Directive (EU) 2024/1760 no longer control.
Operational implication
Record the applicable financial year, entity or group thresholds, and national implementing law for each regime. Do not carry the original CSRD waves or phase-in dates into the workplan.
Binding source for the amended CSRD financial-year rules and CSDDD transposition and application dates.
Enforcement
CSRD
CSRD is tied to assurance of sustainability reporting. The audit framework includes assurance files and reports, independence, quality assurance, investigations, and sanctions through Member State implementation.
CSDDD
is supervised by national authorities with information-gathering, investigation, order, and penalty powers. Directive (EU) 2026/470 requires Member States to set the maximum pecuniary-penalty limit at 3% of net worldwide turnover. It deleted the harmonised civil-liability rule in Article 29(1); compensation now depends on liability under national law, subject to the remaining Article 29 safeguards.
Operational implication
Prepare CSRD information for assurance and conduct for supervisory review. Assess civil exposure under the relevant national law rather than describing CSDDD as a uniform EU damages cause of action.
Binding source for the amended CSDDD supervisory powers, 3% maximum penalty limit, and national-law civil-liability treatment.
Overlap and reuse
CSRD
CSRD disclosures can include due diligence policies, adverse-impact information, value chain impacts, climate transition plans, and sustainability targets where material under ESRS.
CSDDD
Article 16 says the annual CSDDD statement requirement does not apply to companies already subject to sustainability reporting under Articles 19a, 29a, or 40a of the Accounting Directive, including certain exempted companies.
Operational implication
The strongest integration point is communication, not scope. CSRD reporting may satisfy the annual-statement channel for covered reporters, but it does not remove the CSDDD duty to perform due diligence.
Supports the interaction rule in Article 16 for companies already subject to CSRD-style sustainability reporting.
Value-chain and chain-of-activities boundaries
CSRD
ESRS value chain information can cover activities, resources, and relationships from conception to delivery, consumption, and end of life, including upstream and downstream actors where material.
CSDDD
uses the defined concept of . It covers upstream business-partner activities related to production or service provision and specified downstream distribution, transport, and storage activities carried out for or on behalf of the company.
Operational implication
Do not assume the two perimeter terms are identical. Keep a crosswalk showing which suppliers, distributors, logistics partners, products, services, and geographies are covered by each regime.
Supports the CSDDD chain-of-activities definition in Article 3.
Practical decision rule
How should teams plan CSRD and CSDDD work together?
Start with two applicability checks: one for CSRD reporting scope and one for due diligence scope.
Build one source crosswalk, but keep separate columns for ESRS disclosure requirements and due diligence obligations.
Use CSRD materiality and value chain work to inform risk discovery, then document the CSDDD prevention, mitigation, remediation, monitoring, and stakeholder steps separately.
Before publication, check whether CSRD reporting can cover the annual communication requirement for the entity, and keep the legal basis for that conclusion.
Supports use of EFRAG's non-authoritative implementation guidance for CSRD materiality, value chain, and data-point work.
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What belongs in a combined CSRD and CSDDD evidence pack?
A combined workpaper can be useful, but it should not collapse the two regimes into one checklist. Use a crosswalk with separate legal triggers, owners, and evidence, plus a clear statement of which evidence item supports each claim.
For CSRD, the evidence pack should prove why information was included or omitted from the sustainability statement and how the reported data was prepared. For , it should prove what the company did about adverse human rights and environmental impacts.
column: scope conclusion, due diligence policy, risk and impact assessment, prioritisation, prevention or corrective action plan, stakeholder engagement, complaint records, remediation, monitoring, and annual communication.
Overlap column: shared supplier data, shared impact descriptions, shared climate-risk data, shared governance approvals, and the exact source that allows each item to be reused.
Supports the CSDDD evidence categories for due diligence, communication, and monitoring; Directive (EU) 2026/470 controls the later removal of Article 22.
Recommended next step
Build a CSRD and CSDDD source crosswalk
Separate CSRD disclosure evidence from CSDDD due diligence evidence, then document the few places where one record can support both.
Common failure points in CSRD and CSDDD overlap work
The main risk is assuming that similar vocabulary means identical duties. CSRD uses ESRS reporting concepts such as sustainability statement, , value chain, disclosure requirements, and assurance. uses due diligence concepts such as adverse impact, , appropriate measures, complaints procedure, remediation, monitoring, and supervisory authority.
In a combined workpaper, identify which regime creates each duty, what evidence supports performance, and whether the public report also meets the applicable due diligence communication requirement.
Do not label an ESRS materiality assessment as a complete due diligence assessment unless the CSDDD adverse-impact steps are also documented.
Do not use ESRS value chain boundaries as a shortcut for chain-of-activities boundaries without checking Article 3.
Do not cite CSRD assurance preparation as evidence that prevention, mitigation, remediation, or monitoring actions were effective.
Do not publish the original phase-in dates or the former Article 22 climate-plan duty; Directive (EU) 2026/470 replaced those provisions.
Original CSDDD legal text for scope, due diligence actions, chain of activities, monitoring, and communication; Directive (EU) 2026/470 controls the later changes to scope, penalties, and civil-liability provisions.
Supports the CSDDD evidence categories for due diligence, communication, and monitoring; Directive (EU) 2026/470 controls the later removal of Article 22.
Supports the CSDDD side: Article 5 lists the due diligence actions companies must carry out.
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Supports the CSDDD due diligence side through Articles 5 and 7 to 16.
Supports the CSDDD adverse-impact and prioritisation logic in Articles 8 and 9.
Supports the original CSDDD evidence architecture; Directive (EU) 2026/470 must be applied for the current duties and removal of former Article 22.
Supports the interaction rule in Article 16 for companies already subject to CSRD-style sustainability reporting.
Supports the CSDDD chain-of-activities definition in Article 3.
Supports the CSDDD due diligence, monitoring, communication, supervision, and liability side of the planning split.
Supports the amended CSDDD Article 2 thresholds, ultimate-parent routes, consecutive-financial-year test, and removal of the former Article 22 climate-transition-plan duty.