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The EU Corporate Sustainability Due Diligence Directive (CSDDD/CS3D) and Trade Fair Supply Chains: What Changes Through 2027-2029

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  1. 16 July 2026 · corrected by Emir Baycan

    CSDDD's original three-tier employee/turnover threshold structure (1,000/3,000/5,000 employees phased 2027-2029) was changed by the 2025 Omnibus I simplification package (Directive (EU) 2025/794, later Directive (EU) 2026/470), which collapsed the scope to a single tier (more than 5,000 employees and more than EUR 1.5 billion worldwide turnover) and pushed the transposition deadline to 26 July 2028 with application from 26 July 2029. The article's tiered thresholds and 2027/2028/2029 phase-in are the pre-Omnibus version and are now outdated.

    Before

    26 July 2027 for the largest companies (Group 1: ≥5,000 employees and €1.5 billion net worldwide turnover), 26 July 2028 for Group 2 (≥3,000 employees and €900 million turnover), and 26 July 2029 for Group 3 (≥1,000 employees and €450 million turnover).

    After

    26 July 2029, following the 2025 Omnibus I simplification package which collapsed the original three-tier scope into a single threshold of more than 5,000 employees and more than €1.5 billion net worldwide turnover, with transposition pushed to 26 July 2028.

    Why: CSDDD's original three-tier employee/turnover threshold structure (1,000/3,000/5,000 employees phased 2027-2029) was changed by the 2025 Omnibus I simplification package (Directive (EU) 2025/794, later Directive (EU) 2026/470), which collapsed the scope to a single tier (more than 5,000 employees and more than EUR 1.5 billion worldwide turnover) and pushed the transposition deadline to 26 July 2028 with application from 26 July 2029. The article's tiered thresholds and 2027/2028/2029 phase-in are the pre-Omnibus version and are now outdated.

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Emir BaycanExpert Contributor