When will the CSDDD apply?

After Omnibus I, member states must transpose the directive by 26 July 2028 and the rules apply from 26 July 2029.

Does the CSDDD apply directly to small Turkish suppliers?

No. The directive applies only to large companies above the thresholds. Smaller suppliers are affected indirectly, through those companies' information requests and contract terms.

Has the LkSG reporting obligation been removed?

The amending bill would remove the reporting obligation, but as of 8 October 2026 we could not confirm that it has become law. In practice BAFA is reported not to have reviewed reports since autumn 2025, while the due diligence duties continue.

8 October 2026 · 3 min read

CSDDD and LkSG: where do things stand in 2026?

As of 8 October 2026, the EU CSDDD has been narrowed by Omnibus I (2026/470) to companies with more than 5,000 employees and over EUR 1.5 billion turnover, applying from 26 July 2029, while Germany’s LkSG remains in force with its 1,000-employee threshold because the amending bill has not yet been passed.

What is the CSDDD and what did Omnibus I change?

The CSDDD (Corporate Sustainability Due Diligence Directive, 2024/1760) is the EU directive that obliges large companies to identify and prevent adverse human rights and environmental impacts in their own operations and their chains of activities.

The directive was substantially amended by the Omnibus I Directive (2026/470) of 24 February 2026, published in the Official Journal of the EU on 26 February 2026. The amending directive entered into force on the twentieth day after publication.

What are the thresholds and dates in the amended CSDDD?

Item	Position after Omnibus I
EU companies	More than 5,000 employees on average and worldwide net turnover above EUR 1.5 billion
Non-EU companies	Net turnover in the EU above EUR 1.5 billion
Franchising and licensing	Royalties above EUR 75 million and turnover above EUR 275 million
Transposition deadline for member states	26 July 2028
Start of application	26 July 2029
Commission's general due diligence guidelines	By 26 July 2027
Climate transition plan obligation	Removed
EU-wide civil liability regime	Removed; full compensation of victims left to member state law
Maximum fine	3 percent of worldwide net turnover

How does the amended CSDDD affect Turkish suppliers?

Turkish suppliers are not directly addressed by the CSDDD; the obligation sits with the large buyers that exceed the thresholds. Those buyers, however, must carry out in-depth assessments where risks are most likely and most severe, and textile production may be one of those areas.

Omnibus I added a rule to limit the burden passed down the chain: companies in scope may only request necessary information from business partners, and may request it from partners with fewer than 5,000 employees only if they cannot reasonably obtain it another way. This may reduce information requests, but suppliers who already hold ready evidence such as independent audit reports stand out in the process.

Is Germany's LkSG still in force in 2026?

Yes. Germany's Supply Chain Due Diligence Act (LkSG) has been in force since 1 January 2023 and, as of 8 October 2026, has not been amended. The due diligence duties (risk analysis, preventive and remedial measures, a complaints procedure) continue for companies with 1,000 or more employees in Germany.

The German government adopted an amending bill on 3 September 2025; it was submitted to the Bundestag on 29 October 2025 as document 21/2474 and had its first reading in January 2026. Under the bill, the annual reporting obligation would be removed, due diligence duties would continue and only serious breaches would be subject to fines. The LkSG is to be replaced entirely by a new law transposing the CSDDD into German law.

A note on uncertainty: in our check on 8 October 2026 we found no official record of the amending law being passed by the Bundestag or published in the Federal Law Gazette. Secondary sources report that the federal office BAFA has not been reviewing company reports since autumn 2025, and that the coalition agreed on 2 July 2026 to raise the LkSG thresholds to 5,000 employees and EUR 1.5 billion turnover, but we have not yet seen a legal text for that decision. This section will be updated as the legislative process moves on.

What should Turkish suppliers do amid this uncertainty?

Keep your German and EU customers' codes of conduct and supplier questionnaires up to date; legal thresholds may change, but customer requests continue.
Keep your independent social audit reports and corrective action evidence in one place, in a shareable form.
Keep your subcontractor list current; in-depth assessments usually focus on high-risk lower tiers.
Set up a clear complaints channel for your workers and your subcontractors' workers; both the LkSG and the CSDDD treat it as a core element.
Remember that the EU Forced Labour Regulation applies from 14 December 2027, and that regulation does not look at company size.

Frequently asked questions

When will the CSDDD apply?: After Omnibus I, member states must transpose the directive by 26 July 2028 and the rules apply from 26 July 2029.
Does the CSDDD apply directly to small Turkish suppliers?: No. The directive applies only to large companies above the thresholds. Smaller suppliers are affected indirectly, through those companies' information requests and contract terms.
Has the LkSG reporting obligation been removed?: The amending bill would remove the reporting obligation, but as of 8 October 2026 we could not confirm that it has become law. In practice BAFA is reported not to have reviewed reports since autumn 2025, while the due diligence duties continue.