Directives (EU) 2022/2464 & 2024/1760
CSRD & CSDDD
Listrar summary
Two directives that turn supply-chain claims into audited data. CSRD makes large companies report sustainability information under the ESRS standards, with auditor assurance — the first reports, covering 2024, were published in 2025. CSDDD goes further: a duty to actually find and fix human-rights and environmental harm across the chain of activities. Both are in motion — the 2025 'omnibus' package delayed the later reporting waves and pushed CSDDD transposition to 2027, and the scope negotiation is still live. What has not moved: reporters need product- and supplier-level evidence, and they ask their suppliers for it.
Who does it apply to?
- Large EU companies meeting two of three thresholds: 250 employees, €50m turnover, €25m balance sheet (CSRD wave logic)
- Listed SMEs, in a later, lightened wave
- Non-EU groups with significant EU turnover, from FY2028 reporting
- CSDDD: companies above 1,000 employees and €450m worldwide turnover, EU or not
- Indirectly: every supplier of the above, through data requests that flow downhill
Main obligations
- Report under ESRS across environment, social and governance, with double materiality
- Obtain limited assurance on the reported data, moving toward reasonable assurance
- Digitally tag the report (ESEF/XBRL) for machine readability
- CSDDD: identify, prevent, mitigate and account for adverse impacts in your chain of activities
- CSDDD: adopt a climate transition plan compatible with 1.5 °C
Key dates
- 5 January 2023
- CSRD in force
- 2025
- First CSRD reports published, covering FY2024
- April 2025
- 'Stop-the-clock' directive delays waves 2 and 3 by two years; omnibus scope talks continue
- 25 July 2024
- CSDDD in force
- 26 July 2027
- CSDDD transposition deadline (post-omnibus); first application to the largest companies from 2028
Products in scope
- No product scope — these directives bind companies, not goods
- But the data is product-shaped: emissions, materials, origin and labour conditions roll up from records exactly like a registry's
Obligations by actor
- Reporting company
- Publish assured ESRS data; run due diligence; answer for the chain, not just the factory gate
- Supplier
- Provide the upstream evidence — origin, emissions, audits — the reporter cannot invent
- Auditor
- Assure the report; trace claims to records
- Agency / advisor
- Assemble multi-client evidence flows without re-keying data
Documents and evidence to keep
- Supplier-level attestations with validity windows, not annual PDFs
- Emissions and material data traceable to source records
- Due-diligence risk maps and the remediation trail behind them
- Every data point's provenance — ESRS assurance asks where numbers came from
Sanctions and risks
- CSRD: national sanction regimes for missing or false reporting, plus auditor refusal
- CSDDD: supervisory fines with a ceiling of at least 5 % of net worldwide turnover
- CSDDD: civil liability for damage caused by failed due diligence, as transposed
- Commercially immediate: large customers drop suppliers who cannot feed their reporting
Key articles
Official text
Last verified by Listrar: 14 August 2026