From rules to reality: moving the Corporate Sustainability Due Diligence Directive

A central theme throughout the discussions was how companies can move beyond procedural compliance and make due diligence truly impactful:

• How do we shift from tick-the-box exercises to meaningful impact?
• How do we navigate legal uncertainty, for example around the interpretation of “appropriate measures”?
• And ultimately, what does success in due diligence look like?

While definitive answers are still evolving, there was strong alignment on one point: starting matters more than waiting for perfect clarity.

Due diligence as a foundation for resilience

The due diligence principle at the core of the CSDDD goes beyond a single directive. It provides a foundation for more specific legislation, such as the EU Deforestation Regulation and the Forced Labour Regulation.

At its heart, due diligence is about understanding your value chain, and acting on that understanding.

In today’s geopolitical context, with complex and interdependent global value chains, this is no longer just a compliance exercise. Companies that lack visibility over their value chains are more vulnerable to disruptions, whether linked to human rights, environmental risks, or shifting regulatory expectations.

In that sense, not having due diligence in place is increasingly becoming a business risk.

At the same time, knowing your value chain requires collaboration. It means collecting relevant information and aligning expectations with business partners. As a result, the impact does not stop with large companies: SMEs, often positioned as suppliers, are affected through this trickle-down effect.

Key takeaways for companies

Several practical takeaways emerged from the event:

• Start with “no regret” actions: invest in improving supplier visibility and build strong cross-functional collaboration internally.
• Engage suppliers proactively: clearly communicate expectations and work together - disengagement should remain a last resort.
• Collaborate and partner: meaningful due diligence cannot be done in isolation; partnerships are essential.
• Tailor your approach: every company and supply chain is different - design a due diligence approach that fits your business reality.
• Act now: timelines may appear long, but implementation takes time. Starting small is better than delaying.

The need for guidance and harmonisation

Alongside these takeaways, one message stood out clearly: companies need more guidance to implement due diligence effectively. The European Commission is expected to publish a range of guidance documents to support this process. For these to be truly impactful, two elements are critical:

• Harmonisation: consistency in how companies interpret and apply due diligence, as well as alignment among competent authorities
• Practical examples: clear case studies that demonstrate how due diligence can be operationalised in practice

There is also a strong demand for support in applying key concepts, such as risk assessment, including how to assess severity and likelihood in a consistent and actionable way.

What to expect: key milestones for guidance

Looking ahead, the following timeline is expected:

• Before summer 2026: consultation round to gather input for the European Commission
• By 26 July 2027: adoption of general due diligence guidelines
• 26 July 2029: full application deadline of the CSDDD

While these dates provide a roadmap, the message from Brussels was clear: the timeline is shorter than it seems.

Finally, strong due diligence ultimately enables companies to move from a reactive approach to adverse impacts toward a proactive and resilient way of operating.

Want to get started, or curious to learn more? Please reach out.