EU CSDDD Consultation on Implementation Guidance — Revised Scope (5,000 Employees, €1.5B Turnover) and Tier-1 Supplier Focus

The European Commission launched a consultation on draft implementation guidance for the Corporate Sustainability Due Diligence Directive this week, following the Omnibus I amendments that fundamentally reshaped the directive's scope and obligations. The Omnibus I package, which entered into force on March 18, 2026, reduced the CSDDD's scope by approximately 70% — to companies with over 5,000 employees and €1.5 billion in turnover — and narrowed the due diligence obligation from the full "chain of activities" to direct (Tier 1) suppliers, with a risk-based exception allowing firms to go beyond Tier 1 where risks are identified. The mandatory climate transition plan obligation was deleted, as was the EU-wide harmonised civil liability norm. For ESG practice leaders and supply chain counsel advising companies in or near the revised CSDDD threshold, the Commission's draft guidance is the operative implementation document: firms that scoped their due diligence programs under the pre-Omnibus CSDDD should now reassess both their in-scope determination and the depth of their supplier engagement obligations, given that the Tier 1 focus materially changes the documentation and engagement requirements for suppliers beyond the first tier. National transposition is due by July 26, 2028.