From LkSG to CSDDD: what is changing?
For Turkish suppliers already familiar with the German Supply Chain Due Diligence Act (LkSG), the CSDDD (Corporate Sustainability Due Diligence Directive) is a sharper, EU-scale version of the same story. Three differences stand out: the scope is narrower than the LkSG’s and was narrowed further by Omnibus I; sanctions are indexed to turnover (capped at 3% of net worldwide turnover); and civil liability is not harmonised at EU level but left to national law (as of July 2026). Replacing the LkSG with a new act aligned to the CSDDD is stated government policy, but as of July 2026 no such bill has been introduced.
Practical guidance
The new “supplier code” and due-diligence addenda coming from your customers are often written in CSDDD draft language. Negotiate proportionality before signing.
Let us build CSDDD readiness on top of your LkSG file
Our ESG & Supply Chain Desk is at your side for risk analysis, contract architecture, and customer audits.
The timeline: postponed, not cancelled
The directive entered into force in July 2024; however, under the EU’s simplification (Omnibus) agenda, the application timeline was pushed back, and the first wave of companies is expected to become subject to the obligation from 2028 onwards. This postponement does not mean the obligation has disappeared: the procurement and legal departments of large buyers are already moving supplier contracts over to the new language.
How it reaches Turkish suppliers
Through three channels. First, the contract cascade: due diligence annexes containing codes of conduct, audit rights and termination triggers. Second, data requests: risk analysis questionnaires, certificates and incident notifications. Third, commercial elimination: a supplier whose due diligence file is thin drops off the list even when the price is the same. The liability dimension of the CSDDD will only sharpen buyers’ urgency on all three.
How much does your LkSG file already cover?
A risk analysis, policy statement, complaints mechanism and documentation structure built for the LkSG cover a large part of CSDDD preparation. What typically remains missing is documented stakeholder engagement, and a deeper build-out of the “prevention–remediation” steps of the due diligence process. The climate transition plan is not on that list: it sat in Article 22 of the Directive and was repealed in full by Omnibus I ((EU) 2026/470).
Five steps to take now
1) An inventory of the due diligence clauses in customer contracts; 2) a negotiation list of disproportionate commitments; 3) mapping the LkSG file to the CSDDD headings; 4) building the data infrastructure to answer emissions-data requests from customers and from border carbon rules; 5) balanced design of flow-down clauses to sub-suppliers. These steps create value regardless of the directive’s final form.
The LkSG–CSRD–CSDDD triangle: a single-file strategy
The three regulations look at the same supply chain from three angles: LkSG establishes today’s German due diligence obligation, CSRD the reporting and data request, and CSDDD tomorrow’s EU-scale liability. On the supplier side, the most expensive mistake is opening a separate folder for every customer request. The right setup is a single compliance file: one risk analysis, one policy set, one complaints mechanism, one data infrastructure — a single source that can be translated into the language of all three regulations and of every customer. This approach both lowers costs and keeps you consistent under audit.
Five clauses to watch at the contract table
In the due diligence annexes coming from customers, we negotiate these five headings: (1) the scope and cost of the audit right — audit clauses that are unannounced, unlimited and borne by the supplier are disproportionate; (2) termination triggers — a requirement of a documented and unremedied breach instead of vague thresholds such as “suspicion of breach”; (3) sub-supplier commitments — not taking on more than you can pass down your own chain; (4) data and confidentiality — the compliance of shared supplier data with data protection rules; (5) cost sharing — not offloading certification and improvement costs onto one side. These balances are there to be struck, but only at the table; signed in silence, they are gone.
The Köksal approach
Our ESG & Supply Chain Desk knows both the German buyer’s expectations and the reality of Turkish manufacturing, and holds them at the same table. In our ESG & Sustainability focus area, we run risk analysis, contract architecture and customer-audit preparation under a single plan; we extend the structures we built for the LkSG with the CSDDD headings.
Conclusion
The job today is not to wait for the CSDDD, but to manage the contracts that already arrive in its language. A supplier that prepares with a single-file strategy and negotiates knowingly sits down in a stronger position — and holds its place in the European supply chain.
