Governance Briefing — September 23, 2025
With the EU Corporate Sustainability Due Diligence Directive published, companies above the 5,000-employee/€1.5 billion threshold must have draft human-rights and environmental due diligence programs ready for 2027 go-live.
Executive briefing: Directive (EU) 2024/1760 on corporate sustainability due diligence (CSDDD) entered into force on July 25, 2024. The largest in-scope companies—EU and non-EU groups with more than 5,000 employees and €1.5 billion in worldwide net turnover—must comply by July 26, 2027, while smaller cohorts follow in 2028 and 2029. September 2025 is the midpoint for building due diligence governance structures that identify, prevent, mitigate, and remediate adverse human-rights and environmental impacts across operations and value chains, and for drafting the climate transition plan required by Article 22.
Key compliance checkpoints
- Gap assessment. Benchmark existing human-rights, environmental, and supply-chain programs against Articles 6–11 covering risk identification, prevention, mitigation, remediation, and stakeholder engagement.
- Climate plan. Develop a transition plan aligned with the Paris Agreement objective of limiting warming to 1.5 °C, including interim emission-reduction targets and investment strategies.
- Supervisory readiness. Map competent authorities in each Member State of operation and prepare internal reporting lines that can deliver requested information within the directive’s timelines.
Operational priorities
- Stakeholder engagement. Establish consultation forums with affected stakeholders and trade unions, documenting feedback integration as Articles 8 and 9 require.
- Contractual cascading. Update supplier codes of conduct and contractual clauses to mirror due diligence expectations, audit rights, and remediation commitments.
- Remediation funds. Design grievance mechanisms and remediation financing models that can provide compensation or corrective action when adverse impacts are identified.
Enablement moves
- Implement value-chain mapping tools to visualise tier-one and tier-two suppliers, risk scores, and remediation status.
- Align CSDDD disclosures with CSRD double-materiality assessments to streamline reporting obligations.
Sources
- Directive (EU) 2024/1760 on corporate sustainability due diligence
- European Commission CSDDD overview
Zeph Tech maps value-chain risks, orchestrates stakeholder engagement logs, and tracks remediation outcomes for CSDDD supervisors.