CSDDD Implementation Tracker: Staying Ahead of New Guidance and National Implementations Across Europe

This blog was originally posted on 7th July, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY HANNAH JANKNECHT, SENIOR REGULATORY COMPLIANCE SPECIALIST, NGUYEN NGUYEN, REGULATORY COMPLIANCE SPECIALIST, ADHERENT

---

As European member states start transposing the Corporate Sustainability Due Diligence Directive (CSDDD) into national frameworks, staying ahead of divergent requirements poses a significant challenge for companies. This article provides a status update on current legislative progress across Europe, as well as upcoming regulatory guidance.

For a country-by-country overview of implementation status, upcoming EU Commission guidance and key national transposition choices, access our complete CSDDD Implementation Tracker.

Table of Contents

• Core Obligations under the CSDDD
• Omnibus Content Amendment: Changes to Scope and Timeline
• Member State Implementations
• EU Commission Guidance
• CSDDD Implementation Tracking

Core Obligations under the CSDDD

Directive (EU) 2024/1760 on corporate sustainability due diligence (CSDDD) establishes a legal framework requiring in-scope companies to carry out risk-based due diligence regarding human rights and environmental impacts.

To comply with the directive, companies in scope must identify actual or potential adverse impacts and respond in a proportionate manner. Depending on the nature and severity of the risk, this requires taking measures for prevention, mitigation, remediation, or, where allowed by the Directive, responsible disengagement. Additionally, the due diligence framework requires companies to implement complaints procedures, engage with stakeholders, monitor the effectiveness of their policies, and communicate their due diligence efforts publicly.

Omnibus Content Amendment: Changes to Scope and Timeline

Directive (EU) 2026/470 (Omnibus Content Amendment), introduced substantial changes to the CSDDD, in particular the thresholds for applicability. 

The CSDDD now applies to:

• EU companies and groups with more than 5,000 employees and a net worldwide turnover exceeding €1.5 billion,
• Non-EU companies generate a net turnover exceeding €1.5 billion within the European Union, with no employee threshold applied.

In addition, the Omnibus Content amendment postponed the deadlines for CSDDD implementation and application: 

• New Member State implementation deadline: 26 July 2028 
• New Application date for companies: 26 July 2029

Member State Implementations

While the new deadline provides member states with more time to adjust their national laws to the CSDDD, some member states have already started working towards implementing legislation. 

• Finland was the first EU member state to propose a concrete CSDDD draft implementing law in April 2026. 

• Spain has not yet proposed a draft law, but the Spanish Ministry of Economy opened a preliminary public consultation on a draft law in March 2026. The consultation, which closed on 7 April, asked for input regarding company support, industry and sector initiatives, effective enforcement and consumer awareness.

• The Netherlands consulted on a first CSDDD draft implementation in late 2024 (“Wet internationaal verantwoord ondernemen (WIVO)”). The Ministry of Foreign Affairs opened a second consultation on a revised proposed text on 3 July 2026, taking the Omnibus-amendments to the CSDDD into account. Comments on the draft can be submitted until 2 August 2026. The Ministry emphasizes a political commitment to a low-burden implementation without so-called ‘gold-plating’. The draft however contains certain specifications that are necessary to smoothly integrate the new due diligence rules into Dutch law. 

• Germany, France and Norway have not yet started implementing the CSDDD, but they already have national supply chain laws in place, which will have to be adjusted to the new CSDDD framework. 

Further national activity is expected as the 26 July 2028 transposition deadline approaches. 

EU Commission Guidance

To support both enforcement agencies and businesses, the CSDDD requires the EU Commission to adopt a number of guidance documents. This includes guidance on voluntary model contract clauses, due diligence best practice guidance, guidance on stakeholder engagement and guidance for authorities on the determination of penalties. 

As a first step, the Commission opened a 56-question public consultation, requesting input on all of the aspects to be covered in the guidance documents. The consultation period closes on 24 July 2026, and the Commission intends to publish the first official set of guidance documents in the first quarter of 2027. 

CSDDD Implementation Tracking

As national draft laws emerge and existing supply chain acts amended, staying compliant requires continuous monitoring.

To access a granular breakdown of country-by-country progress and upcoming guidance, review our complete CSDDD Implementation Tracker.

See Adherent in Action

Discover how agentic AI is reshaping product compliance for global enterprises.

Book a Demo