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Am I in scope of the CSDDD?

Last updated · 2026-06-08

The Corporate Sustainability Due Diligence Directive (CSDDD, or CS3D) applies directly to only the very largest companies - but many smaller firms feel it indirectly when an in-scope customer asks for due-diligence information. Answer a few plain-English questions and get a tailored steer: whether the directive applies to you directly, indirectly as a business partner, or not at all, and what to do next.

Step 1 of 4

Why are you checking your CSDDD scope?

The Corporate Sustainability Due Diligence Directive (CSDDD, also called CS3D) places direct legal duties on only the very largest companies. But far more businesses feel it indirectly, because an in-scope customer asks them for due-diligence information. Pick the one that fits you.

The short version

How CSDDD scope works

Two things decide whether the directive lands on you directly: where your ultimate parent is established, and how big your group is. A third question - whether a customer is asking you for data - explains why so many smaller firms are affected anyway.

TL;DR

The CSDDD applies directly to EU companies with more than 5,000 employees AND more than €1.5 billion worldwide net turnover, and to non-EU companies with more than €1.5 billion net turnover generated in the EU. In-scope companies apply the rules from 26 July 2029. Smaller companies are not directly regulated, but are pulled in indirectly as suppliers and business partners of in-scope companies.

The size thresholds, post-Omnibus

Omnibus I (Directive (EU) 2026/470, in force 18 March 2026) sharply narrowed who is directly covered. An EU company is in scope only if it exceeds both tests at once: more than 5,000 employees and more than €1.5 billion in worldwide net turnover. A non-EU company has no employee test - the single trigger is more than €1.5 billion in net turnover generated inside the EU. Omnibus I final reforms (Clifford Chance)

The original 2024 thresholds - 1,000+ employees and €450m turnover, phased in by size with a lower bar for high-impact sectors - were removed. The directive now covers an estimated low thousands of companies EU-wide, down from around 6,000.

Groups and the ultimate parent

The thresholds are measured on a group basis, and the obligations fall on the ultimate parent of a group that meets them. Subsidiaries are covered through the group, and the parent can carry out the due diligence on their behalf. Franchising and licensing arrangements are also caught above separate royalty and turnover thresholds. Directive (EU) 2024/1760, as amended

Why smaller firms are still affected

An in-scope company cannot do its own due diligence without information from its business partners. So even if the law never names your company, an in-scope customer will ask you for human-rights, environmental and anti-corruption data - often through a due-diligence questionnaire. The Omnibus value-chain cap exists to stop this getting out of hand: an in-scope company generally should not demand information beyond a standardised set from partners with fewer than 5,000 employees. European Commission, CSDDD overview

National laws may go further

Not being directly in scope of the EU directive does not always mean no duties at all. Some Member States already have their own national supply-chain due-diligence laws with lower thresholds. Check your local rules too, and subscribe to The CSDDD Brief so you hear when the EU rules move again.

Scope questions people ask

What are the CSDDD scope thresholds after Omnibus I?

An EU company is directly in scope if it has more than 5,000 employees AND more than €1.5 billion in worldwide net turnover. A non-EU company is in scope if it generates more than €1.5 billion in net turnover inside the EU, with no employee test. The original 1,000-employee / €450m thresholds and the phased waves were removed by Omnibus I (Directive (EU) 2026/470), so the directive now reaches only the very largest companies.

My company is small but a customer sent me a CSDDD questionnaire. Am I in scope?

Almost certainly not directly. The CSDDD places legal duties only on the largest companies. But an in-scope customer cannot complete its own due diligence without information from its business partners, so it will ask you for it commercially. You are an affected business partner, not a regulated company. Answer proportionately - and note that the Omnibus value-chain cap limits what an in-scope company may demand from partners with fewer than 5,000 employees.

When does the CSDDD start to apply?

Member States must transpose the directive into national law by 26 July 2028. All in-scope companies then apply the rules from a single date, 26 July 2029. First reporting covers financial years starting on or after 1 January 2030, via the CSRD report. The original phased 2027/2028/2029 waves were scrapped by Omnibus I.

Does the CSDDD apply to subsidiaries?

The obligations fall on the ultimate parent company of a group that meets the thresholds. Subsidiaries are covered through the group, and the parent can carry out the due diligence on their behalf. So a subsidiary inside an in-scope group is affected, but the programme is usually run centrally at parent level.

This is guidance to help you understand the CSDDD, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.

Sources

  1. [1]Directive (EU) 2024/1760 (CSDDD), as amended, on EUR-Lexretrieved 8 Jun 2026
  2. [2]European Commission, Corporate sustainability due diligenceretrieved 8 Jun 2026
  3. [3]Clifford Chance, Omnibus I concludes CSDDD and CSRD reforms (Feb 2026)retrieved 8 Jun 2026