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supply chain info corner

The Corporate Sustainability Due Diligence Directive ("CSDDD") represents a significant shift in regulatory and compliance expectations for companies operating in the European Union and beyond. In particular, the Omnibus proposals by the European Commission contribute to more uncertainty. As the directive must be transposed into the national laws of Member States, it is crucial for businesses to stay informed and compliant with these evolving requirements. Our CSDDD Transposition Tracker is designed to provide you with up-to-date information on the implementation status of the CSDDD across the jurisdictions where Schoenherr operates, ensuring you have the necessary guidance to navigate these changes effectively.

The Tracker highlights the current supply chain compliance regimes, the stages of CSDDD implementation, the names of the relevant legislation, the authorities responsible for monitoring compliance, and any instances of gold-plating. While the CSDDD only needs to be transposed into the national laws of Member States, we also include our non-EU jurisdictions, indicating whether similar regimes are in place. This comprehensive overview will help you understand the regulatory landscape and prepare for the implications of the CSDDD in your operations.

We are committed to keeping the Tracker as current as possible, with regular updates based on the latest information. Should there be any amendments or new developments, we will promptly reflect these changes to ensure you have the most accurate and relevant information at your fingertips. 

Click through our map to learn more about the status of CSDDD implementation in each country. 

Information as of: 1 April 2025.

 

Select a country to find out more about the supply chain compliance regime in that country:

AlbaniaAustria | Bosnia & Herzegovina | Bulgaria | Croatia | Czech Republic | Hungary | Moldova | MontenegroNorth Macedonia | Poland Romania | Serbia | Slovakia | Slovenia 

 

Albania

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD 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.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

N/A

 

Gold plating?

N/A

 

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Austria

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD into national law?

There is no published draft legislation yet.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

Not yet known

 

Gold plating?

Not yet known

 

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Bosnia and Herzegovina

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD 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.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

N/A

 

Gold plating?

N/A

 

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Bulgaria

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD into national law?

There is no publicly available draft legislation yet / no information on any initial discussions in the intergovernmental working groups.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

Not yet known

 

Gold plating?

Not yet known

 

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Croatia

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD into national law?

There is no publicly available draft legislation yet / no information on any initial discussions in the intergovernmental working groups.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

Not yet known

 

Gold plating?

Not yet known

 

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Czech Republic

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD into national law?

There is no published draft legislation yet.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

Not yet known

 

Gold plating?

Not yet known

 

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Hungary

Current supply chain compliance regime in place?

Yes

 

Stage of implementation of the CSDDD into national law?

Act CVIII of 2023 ("ESG Act") was adopted at the end of 2023 and came into effect on 1 January 2024. Although the ESG Act does not directly reference the implementation of the CSDDD, it incorporates certain elements of it. Specifically, it imposes supply chain due diligence obligations on businesses falling under its scope. The first ESG reports under the ESG Act are due in 2025.

 

Name of the implementation 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.

 

Responsible authority to monitor 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

 

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Moldova

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD into national law?

Moldova is not an EU Member State; therefore, no implementation is required. There are no plans to pass similar legislation.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

N/A

 

Gold plating?

N/A

 

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Montenegro

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD 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.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

N/A

 

Gold plating?

N/A

 

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North Macedonia

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD 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.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

N/A

 

Gold plating?

N/A

 

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Poland

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD into national law?

There is no publicly available draft legislation yet / no information on any initial discussions in the intergovernmental or parliamentary working groups.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

Not yet known

 

Gold plating?

Not yet known

 

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Romania

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD into national law?

There is no publicly available draft legislation yet / no information on any initial discussions in the intergovernmental working groups.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

Not yet known

 

Gold plating?

Not yet known

 

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Serbia

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD 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.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

N/A

 

Gold plating?

N/A

 

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Slovakia

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD into national law?

There is no publicly available draft legislation yet / no information on any initial discussions in the intergovernmental working groups.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor compliance?

Not yet known

 

Gold plating?

Not yet known

 

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Slovenia

Current supply chain compliance regime in place?

No

 

Stage of implementation of the CSDDD into national law?

There is no publicly available draft legislation yet / no information on any initial discussions in the intergovernmental working groups.

 

Name of the implementation legislation?

N/A

 

Responsible authority to monitor 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

Carina
Fürnkranz

Associate

austria vienna

Stefan
Holub

Attorney at Law

austria vienna

Balkan

Petar
Vučinić

Attorney at Law

montenegro

Bulgaria

Croatia

Ana
Mihaljević*

Attorney at Law in cooperation with Schoenherr

croatia

Czech Republic

Jan
Kupčík

Attorney at Law

czech republic

Hungary

Gábor
Pázsitka

Partner

hungary

Gergely
Horváth

Attorney at Law

hungary

Márk
Kovács

Attorney at Law

hungary

Bálint
Bodó

Associate

hungary

Poland

Katarzyna
Sulimierska

Partner

poland

Romania

Georgiana
Bădescu

Partner

romania

Cristiana
Manea

Managing Attorney at Law

romania

Sabina
Aionesei

Attorney at Law

romania

Slovakia

Michal
Lučivjanský

Partner

slovakia

Slovenia

Matej
Črnilec

Partner in cooperation with Schoenherr

slovenia