Corporate reporting and due diligence (CSRD and CSDDD)
Reporting and due diligence duties for the largest companies. Most independent brands are out of scope and meet the rules as data requests from in-scope buyers.
Directive (EU) 2022/2464 and Directive (EU) 2024/1760, as amended by Directive (EU) 2026/470 (Omnibus I)
Omnibus I in force March 2026. CSRD reporting for companies with more than 1,000 employees and 450 million EUR in net turnover from the financial year 2027. CSDDD applies from July 2029.
Two company-level directives. The Corporate Sustainability Reporting Directive makes the largest companies publish sustainability information to a common standard; the Corporate Sustainability Due Diligence Directive makes the very largest identify and address harm in their chains of activities. Omnibus I, in force since March 2026, cut both back to companies with more than 1,000 employees and 450 million EUR in net turnover for reporting and more than 5,000 employees and 1.5 billion EUR in net turnover for due diligence. Neither creates a passport. A smaller brand meets them as questions from the buyers that are in scope.
Who is in scope after Omnibus I
| Instrument | Who | From when | What it asks |
|---|---|---|---|
| CSRD | Companies with more than 1,000 employees and 450 million EUR in net turnover | Reports for the financial year 2027 onward; the first wave already reports | A sustainability statement to the European standards, covering the value chain as far as information is reasonably available. |
| CSDDD | Companies with more than 5,000 employees and 1.5 billion EUR in net turnover | From July 2029 | A due diligence process: identify, prevent, address and report adverse human rights and environmental impacts in the chain of activities. |
What reaches a brand that is out of scope
- Questionnaires from in-scope buyers, who need your facts for their own statement: where products are made, by whom, from what, under which certificates.
- A ceiling. Omnibus I caps what an in-scope company may ask of a smaller partner at the voluntary standard for SMEs, with an exception for information commonly shared in the sector.
- Contract clauses that pass due diligence duties down the chain, which a brand should read against that cap.
- The same questions from every buyer, which rewards one well-kept record over many spreadsheets.
Neither directive sets a passport field. But a passport shows the countries, facilities and materials behind each product, and that is the evidence a company-level statement rests on. What a brand says about its supply chain in a report or a questionnaire can be read against what its passports show, by a buyer, an auditor or anyone else.
Where brands get caught
- Answering each buyer from a different spreadsheet, so the answers disagree.
- Describing a supplier map you cannot show product by product.
- Signing clauses that ask for more than the cap allows, because nobody checked.
What to prepare
- Keep the supply chain, origins and certificates per style in one place, and answer every questionnaire from it.
- Know your size class and your buyers' size classes; the duties follow theirs, not yours.
- Treat a buyer questionnaire as a preview of the questions an authority could ask under other rules.
One record
What the Seamdex record already carries
- The supply chain by tier with countries and facilities, fibre origin, certificates, weights and substance statements per style and size: the product facts a questionnaire asks for.
- Exports per purchase order or per period, so one answer serves every buyer.
The record carries the product data a report or an answer to an authority rests on. Not a compliance claim: reporting and due diligence duties sit with the company.
FAQ
Questions on this rule
Sources
- Directive (EU) 2022/2464 (EUR-Lex) checked October 2026
- Directive (EU) 2024/1760 (EUR-Lex) checked October 2026
- Directive (EU) 2026/470, Omnibus I (EUR-Lex) checked October 2026
- European Commission, corporate sustainability reporting checked October 2026
- European Commission, corporate sustainability due diligence checked October 2026
Related rules
Regulatory dates last reviewed October 2026. Future dates are expectations, not law. This guide describes the rules; it is not legal advice.
