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Europe | 24 February 2026

Sustainability Due Diligence after the Omnibus: Legal Implications for the CSDDD
Europe
EU
Rule of law
European Green Deal
Trade
Competition

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Sustainability Due Diligence after the Omnibus: Legal Implications for the CSDDD

A legal briefing assessessing the legal and practical implications of the substantive revisions to the CSDDD. 
This briefing offers clear guidance to help all stakeholders understand the revised law and navigate the new framework for sustainability due diligence in the EU. It provides first insights to where regulatory discretion remains for national legislators, where authoritative guidance from the Commission is most urgently needed, and what the revised framework means in practice for companies reassessing their due diligence approaches — including where going beyond the minimum remains advisable.

Key changes explained:

  • ~70% reduction in company scope — from approximately 3,400 corporate groups to roughly 1,000, leaving significant parts of high-risk sectors (agriculture, textiles, mining, construction) unregulated.
  • Preservation of the risk-based approach, unpacking the two-step approach to identifying adverse impacts in line with international standards and the new specifications on information requests to business partners.
  • Deletion of mandatory climate transition plans, which — contrary to stated simplification goals — is likely to increase legal uncertainty and litigation risk for companies.
  • Removal of the harmonised EU civil liability regime, meaning victims' access to justice will now depend on the Member State and applicable law — creating an uneven playing field for both companies and people affected.
  • Maximum fines reduced from 5% to 3% of net worldwide turnover.
Despite these rollbacks, the analysis highlights that the CSDDD remains a pivotal instrument for corporate accountability