Corporate Sustainability Due Diligence DirectiveCSDDD
Directive (EU) 2026/470 changed the CSDDD penalty rule on 18 March 2026. Member states must now cap fines at 3% of net worldwide turnover. The previous text had required them to set a maximum of at least 5%.
- Original instrument
- Directive (EU) 2024/1760
- Amended by
- Directive (EU) 2026/470
- Omnibus I — in force 18 March 2026
- Transposition deadline
- 26 July 2028
- Applies from
- 26 July 2029
- One date for all in-scope companies
- First reports cover
- FY from 1 January 2030
- Maximum penalty
- 3% of net worldwide turnover
- A cap, not a floor
Where these figures come from
Penalty figures traced to Article 27(4) as amended, not to the original directive
Article 27(4) originally required member states to set a maximum penalty of not less than 5% of net worldwide turnover. As amended by Directive (EU) 2026/470 it sets a maximum cap of 3%. The first version set a floor member states had to reach; the amended version sets a ceiling they cannot exceed. Figures on this page are read from the amending directive rather than from the 2024 text.
CSDDD requires large companies to run human rights and environmental due diligence across their operations and value chains. Directive (EU) 2026/470, published in the Official Journal on 26 February 2026 and in force from 18 March 2026, rewrote it substantially: member states must transpose by 26 July 2028 and the rules apply from 26 July 2029 — a single date for all in-scope companies, replacing the original staggered waves. The first reports cover financial years beginning on or after 1 January 2030.
What Directive (EU) 2026/470 removed
Directive (EU) 2026/470 removed the EU-harmonised civil liability regime, so liability now falls to national law. It deleted the climate transition plan obligation. It replaced entity-by-entity value-chain mapping with a risk-based scoping exercise.
Mapping every business relationship was the largest part of the work under the original text. A risk-based scoping exercise requires different evidence.
Dates and figures that changed in March 2026
The staggered application waves were removed. Every in-scope company now shares a single application date of 26 July 2029; descriptions of a first wave in 2027 refer to the original directive.
The 5% penalty figure no longer applies. Article 27(4) now sets 3%, and sets it as a maximum rather than as a minimum member states must reach. The same figure is also frequently attributed to CSRD, which has never carried it.
Penalties
Set nationally within an EU-wide ceiling. Member states decide the regime; the directive now caps how far it can go.
Maximum 3% of net worldwide turnover
Article 27(4), as amended by Directive (EU) 2026/470, sets a uniform maximum cap of 3% of the company's net worldwide turnover. The previous text required a maximum of not less than 5%.
No EU civil liability regime
The harmonised civil liability provisions were removed by Omnibus I. Claims for damages fall to national law, which varies materially between member states.
National detail not yet knowable
Member states have until 26 July 2028 to transpose. Until they do, no country-level penalty figures exist yet.
Does this apply to you?
Scope was narrowed substantially by Omnibus I. Because transposition is not due until 2028, national scope tests may still shift.
- Large EU companies above the size thresholds in the amended directive
- Non-EU companies with sufficient EU turnover
- Smaller companies are reached indirectly, through the requirements their large customers pass down the chain
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Common questions
- What is the CSDDD penalty?
- A maximum of 3% of net worldwide turnover, set by Article 27(4) as amended by Directive (EU) 2026/470. Before 18 March 2026 the directive required a maximum of at least 5%, so the rule changed both in size and in kind — from a floor member states had to reach to a ceiling they cannot exceed.
- When does CSDDD actually apply?
- 26 July 2029, for all in-scope companies at once. Member states must transpose by 26 July 2028. The original staggered waves were removed by Omnibus I.
- Is CSDDD the same as CSRD?
- No. CSRD is a reporting directive; CSDDD is a conduct directive requiring you to act on harms in your value chain. They are frequently confused, and the 5%-of-turnover figure historically attached to CSDDD is one of the most common things wrongly attributed to CSRD.