CSDDD vs CSRD: What Factories Need to Know After Omnibus I

CSRD (Corporate Sustainability Reporting Directive, Directive (EU) 2022/2464) requires large companies to disclose sustainability information in a standard format. CSDDD (Corporate Sustainability Due Diligence Directive, Directive (EU) 2024/1760) requires large companies to identify and address adverse human rights and environmental impacts across their chains of activities. One is a reporting obligation. The other is a due diligence obligation. Both were amended by Directive (EU) 2026/470, known as Omnibus I, and several points commonly repeated about them are now out of date. Complying with CSRD does not mean complying with CSDDD.

What Each Directive Requires

Who Is in Scope, and When Do Obligations Start?

After Omnibus I, CSRD applies to EU companies with more than 1,000 employees and more than EUR 450 million in net turnover, at individual or consolidated level. Non-EU groups are in scope if they generate more than EUR 450 million in net turnover in the EU in each of the last two consecutive financial years and have an EU subsidiary or branch with more than EUR 200 million in net turnover. Listed small and medium-sized companies were removed from scope. The new scope applies from financial years starting on or after 1 January 2027. Member states must transpose the changes by 19 March 2027.

Omnibus I also changed CSDDD. It now covers EU companies with more than 5,000 employees and more than EUR 1.5 billion in net worldwide turnover, and non-EU companies with more than EUR 1.5 billion in net turnover in the EU. Companies must comply from 26 July 2029, and the transposition deadline moved to 26 July 2028. The earlier thresholds of 1,000 employees and EUR 450 million, and the earlier phased start dates, no longer describe current law. If you read a source that quotes them, it predates Omnibus I.

What Changed: Civil Liability and Transition Plans

Two points widely quoted about CSDDD no longer hold. First, the EU-wide civil liability regime was removed. Member states now decide whether failing to meet the due diligence duty creates civil liability under national law, so exposure depends on the country where a claim is brought. Second, the obligation to adopt and put into effect a climate transition plan was removed. Companies that fall under CSRD and have a transition plan must still report on it, but that is a CSRD disclosure, not a CSDDD duty.

Where the Two Directives Still Meet

The real overlap is practical. A large customer may need supplier information for CSRD reporting and for CSDDD due diligence, and the same questionnaire often serves both purposes. The two directives use different concepts of scope. CSRD's value chain covers all operations upstream and downstream, including product end-of-life. CSDDD's chain of activities covers upstream suppliers and limited downstream activities such as distribution, and does not include end-of-life. A company mapping its value chain for ESRS S2 (workers in the value chain) covers more than CSDDD due diligence requires.

What CSDDD Means for Manufacturers Not Directly in Scope

Almost no factory supplying EU brands meets the CSDDD thresholds. But a customer that is in scope must carry out due diligence across its chain of activities, which includes its suppliers. Expect questions about your impacts, your controls and your corrective actions. These requests can start before 2029 as customers build their processes. That timing is editorial judgment, not a legal date.

Omnibus I also introduced a value chain cap for CSRD reporting. In-scope companies generally cannot ask undertakings with an average of no more than 1,000 employees for more than the voluntary sustainability reporting standard for SMEs (VSME), and they can generally rely on those suppliers' self-declarations. Contract terms that undermine the cap are not binding. Whether the same cap limits CSDDD due diligence requests is not covered here, so check it before declining a CSDDD questionnaire.

The ISO 14001 framework helps with either type of request. CSDDD calls for risk-based prioritisation of adverse impacts, which resembles the significant aspects method in ISO 14001. A factory with a working environmental management system already holds the data customers ask for: an aspects register, compliance evaluation records and operational controls. A factory without one will have to build that evidence under customer pressure.

Three Things to Do Before 2029

• List which of your EU customers are likely in scope: more than 1,000 employees and EUR 450 million turnover for CSRD, and more than 5,000 employees and EUR 1.5 billion for CSDDD. Ask them how they plan to collect supplier data.
• Map your adverse environmental and human rights risks, using your ISO 14001 aspects register as a starting point if you have one.
• When a due diligence questionnaire arrives, check its legal basis and your headcount before answering. Respond with documented evidence rather than general statements, and keep a record of what you sent.

References

Directive (EU) 2022/2464 (CSRD). Directive (EU) 2024/1760 (CSDDD). Directive (EU) 2026/470 (Omnibus I), which amends both. Summaries consulted on 8 October 2026: Clifford Chance, Omnibus I: The European Union concludes CSDDD and CSRD reforms (February 2026), and PLMJ, CSRD and CS3D reviewed. Always confirm figures and dates in the Official Journal text.

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