The Corporate Sustainability Due Diligence Directive (CSDDD) is an EU law requiring large companies to identify and address human rights and environmental risks across their own operations and supply chains — and after a significant 2026 revision, it applies to a far smaller group of businesses than it originally did. If you’re a mid-size manufacturer wondering whether this affects you directly, the honest short answer for most is no — but it can still land on your desk indirectly, through a larger customer’s own compliance requirements.
Last updated: 1 September 2026 — this is a living page, tracked as the CSDDD’s implementing guidelines and national transposition progress.
What Is the Corporate Sustainability Due Diligence Directive?
It’s an EU directive requiring large companies to carry out ongoing due diligence on human rights and environmental impacts — not just within their own operations, but across their supply chains and business relationships too. In practice, that means identifying risks like forced labour, unsafe working conditions, or serious environmental harm, taking steps to prevent or mitigate them, and being able to demonstrate that process if challenged.
Who Does the CSDDD Actually Apply To in 2026?
A much narrower group than the original 2024 version proposed. Following the EU’s “Omnibus I” simplification package, which entered into force in March 2026, the thresholds increased substantially: EU companies now need more than 5,000 employees and over €1.5 billion in worldwide turnover to be in scope, while non-EU companies (including UK, US, and Asian parent companies) are captured only if they generate over €1.5 billion in turnover within the EU. That change cut the number of in-scope companies by roughly 70%, down to under 3,000 businesses globally. The timeline shifted too — national transposition is now due by 26 July 2028, with the directive applying from 26 July 2029, and reporting obligations following from the 2030 financial year.
Does the Corporate Sustainability Due Diligence Directive Apply to a Mid-Size Manufacturer Like Yours?
Directly, almost certainly not. If your business sits well under both the 5,000-employee and €1.5 billion turnover thresholds — which covers the overwhelming majority of privately owned, mid-size manufacturers — you are not legally in scope of the CSDDD itself. Indirectly is a different story: if you supply into a large company that is in scope, that company still needs to understand and document risk across its own supply chain, and it will often push due diligence questionnaires, codes of conduct, or contractual requirements down to suppliers like you, regardless of whether you’re legally obligated. That’s the practical way this legislation reaches businesses well below the official thresholds.
What Should You Do About It Now?
Not build a full compliance programme — that would be disproportionate for most mid-size manufacturers given the current scope. It is worth being able to answer basic questions about labour practices and material sourcing if a larger customer asks, since these requests are becoming more common even where they’re not a legal requirement. According to the European Commission’s official CSDDD guidance, implementing guidelines for in-scope companies are still being finalised, so the practical detail of what gets asked of supply chains is likely to firm up over the next year or two — worth revisiting rather than acting on prematurely.
Where Does Novex Fit In?
With operations across the UK, Italy, and Germany, we sit directly inside the EU regulatory environment this directive comes from, and we track it as part of the same ongoing monitoring we apply to our 2026 tariffs and supplier strategy coverage. Supplier-level documentation — the kind a larger customer might eventually ask for — is already part of our supply chain due diligence process under the Supply Focused Methodology.
Frequently Asked Questions
What is the Corporate Sustainability Due Diligence Directive in simple terms?
An EU law requiring large companies to identify, prevent, and address human rights and environmental risks in their own operations and across their supply chains, and to be able to demonstrate that process.
Does the CSDDD apply to small and mid-size businesses?
Directly, no — after the 2026 Omnibus revision, it only applies to EU companies with over 5,000 employees and €1.5 billion in turnover, or non-EU companies generating that much turnover within the EU. Most mid-size manufacturers fall well outside these thresholds.
Why would a smaller supplier need to care about the CSDDD at all?
Because in-scope companies often extend due diligence expectations down their supply chains contractually, even to suppliers who aren’t legally required to comply themselves. A larger EU customer may still ask for documentation on labour and environmental practices.
When does the CSDDD actually take effect?
National transposition is due by 26 July 2028, with the directive applying from 26 July 2029, and reporting obligations for the largest in-scope companies starting from the 2030 financial year.
Has the CSDDD changed recently?
Yes, significantly. The EU’s Omnibus I package, which entered into force in March 2026, raised the employee and turnover thresholds substantially and pushed back the timeline, reducing the number of in-scope companies by roughly 70%.
Talk to Us About Supply Chain Compliance in the EU
If a customer has started asking about your supply chain’s compliance standing, or you just want to understand where you actually sit, get in touch and we’ll help you work out what’s genuinely relevant to your business.
