The Directive requires companies within scope to establish a risk-based due-diligence process across their chains of activities and to prevent/remedy adverse impacts. Omnibus I (2026) removed the climate transition plan obligation and the harmonised EU civil liability regime from the text, leaving compensation to national law. Application was postponed to 26.07.2029; the contracting practice of large buyers is nevertheless already taking shape around this framework.
Overview
The Corporate Sustainability Due Diligence Directive (CSDDD) is the EU’s framework regulation in the field of value chain responsibility. Following national laws such as the German LkSG, it aims to unify the due diligence obligation across the EU.
Scope
The directive directly covers only the largest companies: after Omnibus I (2026), EU companies with at least 5,000 employees and worldwide net turnover above EUR 1.5 billion, together with third-country companies generating more than EUR 1.5 billion of turnover in the EU. Companies below the thresholds — the large majority of Turkish suppliers — are not directly obligated; however, the due diligence processes of covered customers spread down the chain through contracts.
Differences from the LkSG
After Omnibus I the picture is simpler: the CSDDD’s scope is narrower than the LkSG’s; on the sanctions side, turnover-based administrative fines remain, while the harmonised EU civil liability regime and the climate transition plan obligation were removed from the text. Because Germany is expected to run the LkSG as a transitional regime until transposition, investment in LkSG compliance today is preparation for the CSDDD of tomorrow.
Critical point for the Turkish side
Despite the postponed timeline, large buyers are already updating their supplier contracts to match CSDDD language. Against overly broad commitments, negotiated, proportionate due diligence clauses are a Turkish supplier’s most important protection.
Roadmap
On the supplier side, preparation begins with expanding the risk analysis, policy and complaints mechanism established for the LkSG to cover CSDDD headings (stakeholder engagement, proportionate monitoring) and with tracking the due diligence clauses in customer contracts in a single inventory.
Sanctions
After Omnibus I (2026), the ceiling of the administrative fines to be provided for by member states may not exceed 3% of net worldwide turnover. The harmonised EU civil liability regime was removed from the text: compensation is left to national law under a review clause, while the procedural protections on access to evidence remain.
Related content
For comparison, see the LkSG entry and, for the reporting counterpart, the CSRD entry. We address the preparation steps for Turkish suppliers in our detailed analysis and the implementation in our ESG focus area.
