Brüssel arbeitet derzeit an einem EU-Richtlinienentwurf für Lieferketten. Das deutsche Gesetz ist bereits in Kraft – und bringt für viele österreichische Betriebe Neuerungen
supply chain info corner
The Corporate Sustainability Due Diligence Directive ("CSDDD") establishes a comprehensive framework for sustainable business conduct in the EU. It requires in-scope companies to conduct risk-based due diligence with respect to adverse human rights and environmental impacts covering their own operations as well as those of their subsidiaries and their "chain of activities". Following the omnibus amendments (Directive 2026/470), the directive now applies only to the very largest companies: EU companies with more than 5,000 employees and a net worldwide turnover exceeding EUR 1.5 billion, and non-EU companies generating more than EUR 1.5 billion net turnover in the EU. In addition, the directive captures companies of franchising or licensing arrangements in the EU where royalties exceed EUR 75 million and net turnover exceeds EUR 275 million (for EU companies, worldwide; for non-EU companies, generated in the EU). Companies meeting these thresholds for two consecutive financial years will be subject to the directive from 26 July 2029.
Although the directive still needs to be transposed into national law by EU Member States (deadline: 26 July 2028), in-scope companies are well advised to prepare for the new compliance obligations well in advance.
- Scoping business activities: In-scope companies should already start scoping their chain of activities. Following the omnibus amendments, companies are now required to carry out a two-stage process: first, a scoping exercise based solely on reasonably available information to identify general areas where adverse impacts are most likely to occur and to be most severe; and second, an in-depth assessment only in the areas identified as high-risk.
- Updating and enhancing compliance management systems: Companies should adopt and regularly update risk-based due diligence policies and integrate due diligence processes within their risk management systems and internal controls. In addition, companies should assign clear roles and responsibilities in line with best practice compliance management systems. This also includes monitoring the effectiveness of policies and measures.
- Implementing tailored compliance documentation: It is of utmost importance to adopt compliance-proof documentation outlining the rules and principles that in-scope companies and subsidiaries must adhere to, such as codes of conduct for subsidiaries and/or business partners. Already existing documents need to be reassessed and potentially adjusted to align with the CSDDD requirements.
- Preparing business partners for the new obligations of in-scope companies: Preparing business partners of in-scope companies to play an important role in the upcoming due diligence processes is arguably one of the most delicate aspects. Business partners will need to provide information to in-scope companies – however, the omnibus amendments have introduced important protections. This not only presents commercial challenges but also involves navigating through various legal obstacles, necessitating cautious approaches to avoid collision with other laws (e.g. competition law, data protection, etc.). Both in-scope companies and their business partners should therefore know their duties and obligations under the CSDDD as well as the boundaries of other laws.
- Providing guidance and training: Every successful compliance management system provides for guidance and training of employees. In-scope companies should use the time until application wisely to set up a training programme creating awareness among employees who are in regular contact with suppliers and customers. This includes a "tone from the top" approach that underpins the company's values and ethics. The Commission is expected to adopt general due diligence guidelines by 26 July 2027, which will provide valuable practical guidance for companies.
- Key enforcement aspects: The omnibus amendments have also adjusted the enforcement framework. Pecuniary penalties are now capped at a maximum of 3% of the company's net worldwide turnover (previously, the minimum threshold was 5%). Civil liability is now governed by applicable national law, with Member States required to ensure that victims can obtain full compensation where a company is held liable for a failure to comply with the due diligence requirements.
In addition to advising clients on the CSDDD, Schoenherr's experts also provide interdisciplinary and full-service capabilities and advise on other supply chain aspects as well. Notably, this includes obligations stemming from national supply chain laws and impacts on companies, for instance the German Supply Chain Act and its impacts on non-German companies and suppliers.
Click through our map to learn more about the status of CSDDD implementation in each country.
Information as of: 1 September 2026.
Select a country to find out more about the supply chain compliance regime in that country:
Albania | Austria | Bosnia & Herzegovina | Bulgaria | Croatia | Czech Republic | Hungary | Moldova | Montenegro | North Macedonia | Poland | Romania | Serbia | Slovakia | Slovenia
Albania
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
Albania is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
N/A
Gold plating?
N/A
Austria
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
There is no published draft legislation yet. The omnibus directive (Directive (EU) 2026/470) further extended the transposition deadline by an additional year: Member States must now adopt and publish the laws, regulations and administrative provisions necessary to comply with the CSDDD by 26 July 2028.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
Not yet known
Gold plating?
Not yet known
Bosnia and Herzegovina
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
Bosnia & Herzigovina is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
N/A
Gold plating?
N/A
Bulgaria
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
There is no published draft legislation yet. The omnibus directive (Directive (EU) 2026/470) further extended the transposition deadline by an additional year: Member States must now adopt and publish the laws, regulations and administrative provisions necessary to comply with the CSDDD by 26 July 2028.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
Not yet known
Gold plating?
Not yet known
Croatia
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
There is no published draft legislation yet. The omnibus directive (Directive (EU) 2026/470) further extended the transposition deadline by an additional year: Member States must now adopt and publish the laws, regulations and administrative provisions necessary to comply with the CSDDD by 26 July 2028.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
Not yet known
Gold plating?
Not yet known
Czech Republic
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
There is no published draft legislation yet. The omnibus directive (Directive (EU) 2026/470) further extended the transposition deadline by an additional year: Member States must now adopt and publish the laws, regulations and administrative provisions necessary to comply with the CSDDD by 26 July 2028.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
Not yet known
Gold plating?
Not yet known
Hungary
Is a supply chain compliance regime currently in place?
Yes
What is the current stage of CSDDD implementation into national law?
There is no published draft legislation yet. The omnibus directive (Directive (EU) 2026/470) further extended the transposition deadline by an additional year: Member States must now adopt and publish the laws, regulations and administrative provisions necessary to comply with the CSDDD by 26 July 2028.
What is the name of the implementing legislation?
No formal implementation yet. However, the ESG Act has pre-emptively incorporated certain elements of the CSDDD. Please refer to the question before this one for more details.
Which authority is responsible for monitoring compliance?
No formally designated authority yet. The Supervisory Authority for Regulated Activities (in Hungarian: Szabályozott Tevékenységek Felügyeleti Hatósága) monitors compliance with the ESG Act. Please refer to the second question for more details.
Gold plating?
N/A
Moldova
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
Moldova is not an EU Member State; therefore, no implementation is required. There are no plans to pass similar legislation.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
N/A
Gold plating?
N/A
Montenegro
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
Montenegro is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
N/A
Gold plating?
N/A
North Macedonia
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
North Macedonia is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
N/A
Gold plating?
N/A
Poland
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
There is no published draft legislation yet. The omnibus directive (Directive (EU) 2026/470) further extended the transposition deadline by an additional year: Member States must now adopt and publish the laws, regulations and administrative provisions necessary to comply with the CSDDD by 26 July 2028.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
Not yet known
Gold plating?
Not yet known
Romania
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
There is no published draft legislation yet. The omnibus directive (Directive (EU) 2026/470) further extended the transposition deadline by an additional year: Member States must now adopt and publish the laws, regulations and administrative provisions necessary to comply with the CSDDD by 26 July 2028.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
Not yet known
Gold plating?
Not yet known
Serbia
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
Serbia is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
N/A
Gold plating?
N/A
Slovakia
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
There is no published draft legislation yet. The omnibus directive (Directive (EU) 2026/470) further extended the transposition deadline by an additional year: Member States must now adopt and publish the laws, regulations and administrative provisions necessary to comply with the CSDDD by 26 July 2028.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
Not yet known
Gold plating?
Not yet known
Slovenia
Is a supply chain compliance regime currently in place?
No
What is the current stage of CSDDD implementation into national law?
There is no published draft legislation yet. The omnibus directive (Directive (EU) 2026/470) further extended the transposition deadline by an additional year: Member States must now adopt and publish the laws, regulations and administrative provisions necessary to comply with the CSDDD by 26 July 2028.
What is the name of the implementing legislation?
N/A
Which authority is responsible for monitoring compliance?
Not yet known
Gold plating?
Not yet known
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If you do have any questions about The Corporate Sustainability Due Diligence Directive ("CSDDD"), please do not hesitate to contact us.
Austria
Johannes
Frank
Partner
austria vienna
Stefan
Holub
Attorney at Law
austria vienna
Balkan
Srđana
Petronijević
Partner
serbia
Danijel
Stevanović
Partner
serbia
Petar
Vučinić
Attorney at Law
montenegro
Bulgaria
Elena
Todorova
Counsel
bulgaria
Alexandra
Minioti
Associate
bulgaria
Croatia
Ana
Mihaljević*
Attorney at Law in cooperation with Schoenherr
croatia
Czech Republic
Jan
Kupčík
Counsel
czech republic
Hungary
Gábor
Pázsitka
Office Managing Partner
hungary
Gergely
Horváth
Attorney at Law
hungary
Márk
Kovács
Attorney at Law
hungary
Anna
Turi
Counsel
hungary
Poland
Katarzyna
Sulimierska
Partner
poland
Ewelina
Adamczyk
Attorney at Law
poland
Romania
Georgiana
Bădescu
Partner
romania
Cristiana
Manea
Managing Attorney at Law
romania
Sabina
Aionesei
Senior Attorney at Law
romania
Slovakia
Michal
Lučivjanský
Partner
slovakia
Slovenia
Matej
Črnilec
Partner in cooperation with Schoenherr
slovenia