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Sustainability reporting and Due Diligence in the EU after Directive (EU) 2026/470

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Illustration of EU sustainability reform under Directive (EU) 2026/470, highlighting reporting and due diligence requirements for large undertakings

Directive (EU) 2026/470, adopted on 24 February 2026 and published in the Official Journal on 26 February 2026, amends EU corporate sustainability reporting and corporate sustainability due diligence rules by narrowing scope, introducing value chain protections, removing the transition to reasonable assurance, and reshaping the Corporate Sustainability Due Diligence Directive (CSDDD).

The reform restructures the EU sustainability framework while preserving its core architecture.

Key regulatory changes

CSRD scope: new mandatory thresholds

Mandatory sustainability reporting now applies only to undertakings that exceed both:

Both criteria must be met cumulatively.

The revised scope applies to individual undertakings, groups, insurance undertakings, and credit institutions.

The reporting perimeter is therefore concentrated on the largest economic actors.

Listed SMEs removed from mandatory reporting

Small and medium-sized undertakings whose securities are admitted to trading on a regulated market are excluded from mandatory sustainability reporting.

The empowerment to adopt SME-specific sustainability reporting standards is removed.

Voluntary sustainability reporting remains available through standards for voluntary use.

Value chain cap: statutory protection for suppliers

Directive (EU) 2026/470 introduces formal protections for undertakings in the value chain with up to 1,000 employees (“protected undertakings”).

Reporting undertakings:

Any contractual clause requiring information beyond these limits for CSRD reporting purposes is not binding.

This provision limits ESG data extraction within supply chains and creates a statutory refusal right for smaller undertakings.

ESRS revision mandate

Within six months of entry into force, the Commission must revise the first set of European Sustainability Reporting Standards to:

Mandatory sector-specific standards are removed. The Commission may issue sector-specific guidance instead.

Assurance framework

The Commission must adopt limited assurance standards by 1 July 2027. The obligation to transition to reasonable assurance standards is removed.

Limited assurance therefore becomes the structural ceiling unless future legislation changes the framework.

For third-country auditors issuing sustainability assurance reports, a transitional registration regime applies for financial years between 1 January 2025 and 31 December 2030.

Omission of sensitive information

Undertakings may omit sustainability information, subject to assurance, where disclosure would:

This formalises proportionality and security safeguards within sustainability reporting.

Digital reporting clarification

Until digital marking-up rules for sustainability reporting are adopted under the EU electronic reporting framework, undertakings are not required to digitally tag sustainability reporting.

This reduces immediate digital implementation burdens.

Third-country reporting thresholds increased

The directive raises:

This narrows the extraterritorial reach of the reporting regime.

Key Dates · 2026 – 2029

Regulatory Timeline
From publication through to full application of revised due diligence rules.
24 Feb 2026
Directive (EU) 2026/470 Adopted
Published in the Official Journal 26 Feb 2026. Entry into force begins.
Within 6 months of entry into force
Commission Revises ESRS
Datapoints rationalised; mandatory vs. voluntary distinctions clarified; sector-specific mandatory standards removed.
1 July 2027
Limited Assurance Standards Adopted
Limited assurance becomes the permanent ceiling. Transition to reasonable assurance obligation removed.
1 Jan 2025 – 31 Dec 2030
Third-Country Auditor Transition Period
Transitional registration regime for third-country auditors issuing sustainability assurance reports.
26 July 2029
CSDDD Applies to All Companies
Full application for all undertakings exceeding 5,000 employees and €1.5 billion turnover.

CSDDD after Directive (EU) 2026/470

Directive (EU) 2026/470 substantially amends Directive (EU) 2024/1760.

CSDDD now applies only to companies exceeding:

The directive:

What this means for companies

If you exceed €450 million turnover and 1,000 employees, sustainability reporting remains mandatory. You should reassess:

If you fall below thresholds but operate within supply chains, you may:

The sustainability reporting environment for 2027–2029 is now legally defined, proportionate in scope, and structurally more targeted toward the largest undertakings.

Frequently Asked Questions

Does Directive (EU) 2026/470 remove CSRD?

Are listed SMEs still required to report under CSRD?

Will reasonable assurance still apply to sustainability reporting?

When does the revised CSDDD apply?

No. It narrows scope to undertakings exceeding €450 million turnover and 1,000 employees.

No. Mandatory reporting for listed SMEs has been removed.

No. The transition to reasonable assurance has been removed. Limited assurance becomes the structural ceiling.

From 26 July 2029.

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