The Corporate Sustainability Due Diligence Directive: tracking transposition and goldplating across the EU

The Corporate Sustainability Due Diligence Directive (CS3D) is EU legislation subjecting in-scope companies to far-reaching due diligence obligations in relation to the adverse human rights and environmental impacts of their own operations as well as those of their subsidiaries and their upstream and downstream “chain of activities”. It also requires them to adopt and implement transition plans for climate change mitigation in line with the Paris Climate Agreement.

Following a roller-coaster legislative process that started in February 2022, the CS3D came into force in July 2024.

This is not the end of the legislative process. EU Member States now need to transpose the directive into national law by adopting their own implementation acts. They have until 26 July 2026 to do this, and their national laws must apply from mid-2027 to mid-2029 to in-scope companies depending on their size.