CSRD, CSDDD and EUDR: which is which, and which applies to you
CSRD, CSDDD and EUDR are often confused. A common error is attributing a 5% of turnover penalty to CSRD — that figure belonged to CSDDD and has since changed. One is a reporting rule, one a conduct rule, one a market-access rule; each binds different entities for different reasons.
CSRD requires sustainability information to be reported. CSDDD requires action on harms in the value chain. EUDR conditions the right to place certain commodities on the EU market on deforestation-free sourcing. CSRD applies to large EU companies and certain non-EU groups above size thresholds; CSDDD to large companies from 26 July 2029; EUDR to anyone placing seven listed commodities on the EU market from 30 December 2026 for large operators, regardless of size or establishment.
Reporting, conduct and market access
CSRD governs disclosure: what to publish and to what standard. Compliance means producing a report that survives assurance.
CSDDD governs conduct: identifying, preventing and accounting for adverse impacts. Compliance means changing operations; a report of an unchanged supply chain does not satisfy it.
EUDR governs market access: the right to sell a product. Compliance means holding plot-level evidence before goods move. No report substitutes for the data.
The 5% figure and where it belongs
Where this usually goes wrong
It was never a CSRD figure. CSRD sets no EU-wide penalty — Article 51 leaves penalties to national law, and verified maxima range from roughly €600 in Romania to €10,000,000 in Italy.
It was a CSDDD figure, and no longer applies as originally drafted. Directive (EU) 2026/470, in force from 18 March 2026, replaced the requirement for a maximum of at least 5% with a uniform cap of 3%.
Who each regime catches
Size decides CSRD and CSDDD. Product decides EUDR. A mid-sized coffee importer with 80 employees can be out of scope of both disclosure directives and in scope of EUDR, with the harder data problem.
A large services group can be deep in CSRD and CSDDD and outside EUDR, because it places no physical commodities on the market.
Questions people actually ask
- What is the difference between CSRD and CSDDD?
- CSRD is a reporting directive — it governs what you disclose. CSDDD is a conduct directive — it governs what you do about harms in your value chain. A compliant CSRD report does not demonstrate CSDDD compliance.
- Does CSRD carry a fine of 5% of turnover?
- No. CSRD sets no EU-wide penalty; Article 51 delegates it to national law. The 5% figure came from CSDDD, and was replaced in March 2026 by a 3% maximum.
- Can a small company be in scope of EUDR but not CSRD?
- Yes, and it is common. EUDR follows the commodity, not the company, so a small importer of coffee, cocoa or timber is in scope regardless of size, while remaining below CSRD thresholds.
Still not sure what binds you?
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