A new joint publication by ClientEarth and Frank Bold sheds light on how the Omnibus I revision has reshaped the Corporate Sustainability Due Diligence Directive (CSDDD) — and what this means for companies, regulators, and stakeholders across the EU.
The legal briefing, Sustainability Due Diligence after the Omnibus: Legal Implications for the CSDDD, provides the first legal analysis of the amended Directive. It gives an overview of the main changes and their interactions, and explains some of the more practical implications for companies.
"The final Omnibus approval is not a green light for companies to step back. While the revision significantly narrows the number of companies directly in scope, the core obligations to effectively prevent and address harm across the operations and in the value chains remain. Companies that scale back their due diligence efforts are taking a gamble. The physical, reputational, and litigation risks have not shrunk — in some areas, they have grown. Robust due diligence remains the smartest risk management tool a company can have." - Julia Otten, Senior Policy Officer at Frank Bold
One of the most significant changes is the drastic reduction in the number of companies covered. The Omnibus raises the thresholds to 5,000 employees and €1.5 billion turnover, reducing the scope by an estimated 70%.
This change leaves significant parts of high-risk-sectors, such as textiles, mining, or construction out of scope. It remains to be seen how the very large companies in scope contribute to improving due diligence processes at the level of their business partners in the supply chains. A new review clause in 2031 offers a chance to revisit this limitation.
The revision kept the risk-based approach to identification. Our brief unpacks the two-step approach to identifying adverse impacts in line with international standards and the new specifications on information requests to business partners.
While mandatory climate transition plans were removed from the CSDDD, the obligations related to the disclosure of climate transition plans still remain under CSRD. We explain what this means.
The Omnibus removes the harmonised EU civil liability regime and the possibility for representative actions. This means victims’ access to remedy will now depend heavily on national laws — and may vary widely across Member States.
Our analysis warns that the deletion of the overriding mandatory provision (OMP) creates significant unpredictability for victims, companies, and courts alike.
Despite the weakened framework, the CSDDD remains a landmark piece of EU legislation. Large companies active in the EU market must identify, prevent, mitigate, and remediate human rights and environmental harms across their operations and value chains.
Companies retain the opportunity to go beyond existing requirements and demonstrate leadership, especially ahead of the 2031 review.
As Member States begin transposition and companies prepare for implementation, clarity on the legal implications of the Omnibus is essential. Our joint publication provides a roadmap for navigating these challenges.
The Frank Bold expert group continues its long-term support for Ukraine in 2026. As the fourth year of Russian aggression draws to a close, Frank Bold is sending another financial contribution to support the country’s defenders through the Ukrainian foundation Come Back Alive.
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