CSDDD after Omnibus I: the 2029 timeline and what suppliers will be asked

The EU Corporate Sustainability Due Diligence Directive has been rewritten. After the Omnibus I package, far fewer companies are in scope and the start date is later. For suppliers in Türkiye, Asia or North Africa that sounds like relief. In practice, the questions keep coming.

What changed

Directive (EU) 2026/470 was published in the Official Journal on 26 February 2026, after the Council's final approval on 24 February.12 The main points:

• Scope: EU companies with more than 5,000 employees and more than €1.5bn worldwide net turnover; non-EU companies with more than €1.5bn turnover in the EU.3
• Timeline: transposition by 26 July 2028, application from 26 July 2029, one date for all.3
• Risk-based approach: a scoping exercise based on reasonably available information, followed by in-depth assessment where impacts are most likely and severe.2
• No climate transition plan under the CSDDD any more, and no harmonised EU civil liability; fines capped at 3% of worldwide turnover.2

Why suppliers will still be asked

The directive applies to large companies, but their due diligence covers their chain of activities. To identify and prevent adverse impacts, they rely on contractual assurances and information from business partners. Their suppliers are where the data sits.

Germany adds a second layer: the Supply Chain Due Diligence Act (LkSG) already applies to companies with 1,000 or more employees in Germany. The authority BAFA stopped reviewing annual reports in October 2025, but the due-diligence duties remain in force.4 German buyers therefore keep sending questionnaires today, not only from 2029.

What you will be asked

• Child and forced labour, wages, working hours, health and safety.
• Freedom of association and non-discrimination.
• Environmental management, waste and hazardous substances.
• Your grievance channel and how cases are handled.
• Whether you pass similar requirements to your own suppliers.

How to answer efficiently

The questionnaires differ in wording but overlap in substance. Build one set of answers with evidence, keep it current, and reuse it. State gaps honestly together with a plan and a date; an empty field reads worse than “not yet, planned for Q1”.

That is the idea behind the Compass supplier file: answer once, release per customer.