Policy Briefing — CSDDD largest-company cohort prepares for 2027 duty of care

Executive briefing: Directive (EU) 2024/1760 obliges companies exceeding 5,000 employees and €1.5 billion global turnover to comply with the Corporate Sustainability Due Diligence Directive (CSDDD) three years after entry into force, i.e., in 2027. After the July 2026 transposition deadline, multinationals now have one quarter left to lock governance, contract, and remediation frameworks before supervisors begin enforcement.

Mandatory deliverables

• Due diligence policy. Articles 4–6 require risk-based policies, upstream and downstream value-chain mapping, and integration into corporate governance.
• Remediation and complaints handling. Articles 7–9 mandate mitigation plans, stakeholder engagement, and grievance mechanisms covering human-rights and environmental harms.
• Climate transition plans. Article 15 obliges alignment with the Paris Agreement, including emission reduction targets and board oversight.

Program actions

• Legal harmonisation. Reconcile national transposition measures with existing supply-chain laws (e.g., Germany’s LkSG, France’s Loi de vigilance) to avoid conflicting obligations.
• Contract refresh. Insert CSDDD-compliant clauses on audit rights, remediation duties, and termination triggers across high-risk suppliers.
• Supervisory liaison. Engage designated national authorities to clarify reporting templates, penalty regimes, and cross-border cooperation arrangements.

Enablement moves

• Integrate CSDDD controls with CSRD disclosures to demonstrate consistent treatment of double materiality findings and due diligence outcomes.
• Test grievance mechanisms with workers, unions, and civil society partners to evidence accessibility ahead of 2027 enforcement.

Sources

• Directive (EU) 2024/1760 — Corporate Sustainability Due Diligence Directive
• Council of the EU — CSDDD adoption press release