EU narrows corporate due diligence rules in final Omnibus approval
Final Omnibus approval raised the scope thresholds for EU corporate reporting and due diligence, removed the harmonised liability regime and pushed company compliance under CSDDD to 2029.
- Development
- 24 February 2026
- Published
- 28 October 2026
- Sources checked
- 29 October 2026
Two regimes, higher thresholds
The Council of the European Union approved Directive (EU) 2026/470 on 24 February 2026, changing two distinct frameworks: the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). For EU companies under CSRD reporting, the new threshold is more than 1,000 employees and net annual turnover above €450 million. For EU companies under CSDDD conduct duties, it is more than 5,000 employees and net turnover above €1.5 billion. Both tests use the stated employee and turnover conditions.
The Council’s announcement of final approval completed the EU legislative step; it did not mean every company had to comply that day. The directive sets separate transposition and application dates, with implementation determining when obligations apply in practice.
Risk assessment and supplier scrutiny
For companies within scope, the directive revises how supply-chain risks are assessed. It permits a risk-based approach using information that is reasonably available, and allows firms to prioritise direct business partners when adverse impacts are equally likely or equally severe at different levels of the chain. The Council’s account of the adopted changes describes a framework in which assessment need not proceed as an identical, exhaustive inquiry into every supplier at once.
The directive removes the CSDDD requirement for companies to adopt a climate transition plan and removes the EU-harmonised civil liability regime. National liability rules and national duty-of-vigilance laws remain separate matters; the directive does not repeal all corporate liability or every national supply-chain duty.
The timetable for implementation
The Council announcement sets 26 July 2028 as the CSDDD transposition deadline and July 2029 for companies to comply with the new measures. Those dates distinguish an adopted amending directive from the later application of company duties. CSRD reporting changes have their own implementation provisions.
Our analysis: suppliers assessing a customer’s questionnaire need to identify which regime the customer means. A request for sustainability information and a request to investigate an adverse impact serve different purposes. Higher thresholds do not answer every question about a supply relationship; national law and the applicable implementation provisions still need to be checked for the business concerned.