Key data
| Regulation | Corrigendum to Directive (EU) 2024/1760 on corporate due diligence for sustainability (CSDDD) |
|---|---|
| Reference | CELEX:32024L1760R(03) |
| Publication | 10 March 2026 |
| Entry into force | 5 July 2024 (original directive) |
| Affected parties | Large companies with more than 1,000 employees and more than 450 million euros of annual turnover |
| Maximum penalty | Up to 5% of net worldwide turnover |
| Category | Business Regulation |
| Type of correction | Technical — does not alter substantive obligations |
If your company exceeds 1,000 employees and 450 million euros of annual turnover, Directive (EU) 2024/1760 — known as CSDDD — already applies to you. The corrigendum published on 10 March 2026 with reference CELEX:32024L1760R(03) changes nothing substantive: the obligations, timelines and penalties remain the same. What is important to clarify is what exactly this directive requires and what real economic risk non-compliance poses.
What does this regulation establish?
The CSDDD requires large companies to act actively and in a documented manner against the risks that their activity — and that of their suppliers — may generate on human rights and the environment. Having a sustainability policy on paper is not enough: the directive requires concrete and verifiable processes.
The three main obligations established by the directive are:
- Due diligence plan: identify, prevent and mitigate adverse impacts on human rights and the environment throughout the entire supply chain.
- Whistleblowing channel: internal mechanism that allows workers, suppliers and third parties to report breaches safely.
- Climate transition strategy: plan that aligns the company's business model with the objectives of the Paris Agreement.
This corrigendum also affects Directive (EU) 2019/1937 and Regulation (EU) 2023/2859, which are amended by the original directive. The corrections are exclusively technical in nature and do not alter any of these obligations.
Transposition into Spanish law must be carried out within the timelines established by the original directive. Until Spanish transposition legislation exists, companies must prepare to comply with the European framework.
Economic and operational impact
The impact is not only reputational: it is economic and operational. Affected companies must bear real implementation costs and, above all, manage the risk of penalties.
| Concept | Detail |
|---|---|
| Maximum penalty for non-compliance | Up to 5% of net worldwide turnover |
| Implementation cost | Not set by the directive; depends on the size and complexity of the supply chain |
| Scope of due diligence | Entire supply chain, not just own operations |
| Required documentation | Due diligence plan, whistleblowing channel, climate transition strategy |
The greatest operational impact is in supplier management: obligated companies will need to audit, map and in many cases renegotiate contracts with their supply chain to ensure compliance. This has a direct cost in human resources, systems and management time.
Who does it affect?
The directive applies directly to companies that simultaneously meet both thresholds:
- More than 1,000 employees
- More than 450 million euros of annual turnover
Even if your company does not reach these thresholds, it may be indirectly affected if it is part of the supply chain of an obligated company. In that case, the large customer will require you to comply with their due diligence standards as a contractual condition.
The sectors with the highest exposure are:
- Manufacturing industry with international supply chains
- Distribution and fast-moving consumer goods
- Textiles and fashion
- Food and agriculture
- Mining and raw materials
- Technology and electronics
- Construction and infrastructure
Practical example
A Spanish food sector company with 1,200 employees and 600 million euros of annual turnover falls directly within the scope of the CSDDD.
If this company does not implement a due diligence plan covering its agricultural supply chain — for example, suppliers in countries with risk of child labour or environmental damage — it is exposed to a penalty of up to 5% of its net worldwide turnover. With 600 million euros of turnover, this equates to a potential fine of up to 30 million euros.
In addition, it must enable an accessible whistleblowing channel for workers and suppliers, and develop a climate transition strategy aligned with the Paris Agreement. These three elements must be documented and verifiable before the competent authorities.
What should companies do now?
- Verify if you fall within the scope of application: check whether your company exceeds 1,000 employees and 450 million euros of annual turnover. If so, the directive applies directly to you.
- Map your supply chain: identify all direct and indirect suppliers and assess risks regarding human rights and the environment at each link.
- Develop the due diligence plan: document the processes to identify, prevent and mitigate adverse impacts. This plan must be operational, not merely declarative.
- Implement a whistleblowing channel: enable an accessible and secure mechanism for workers, suppliers and third parties to report breaches.
- Develop the climate transition strategy: develop a plan that aligns your business model with the climate objectives of the Paris Agreement.
- Review supplier contracts: include due diligence compliance clauses in contracts with your supply chain.
- Monitor Spanish transposition: track when Spain transposes the directive into national law to learn the final timelines and competent control authorities.
The risk of inaction is concrete: penalties of up to 5% of net worldwide turnover and exposure to civil claims for damages caused in the supply chain.
Frequently asked questions
Which companies does the CSDDD due diligence directive on sustainability affect?
It affects large European companies with more than 1,000 employees and more than 450 million euros of annual turnover. If your company does not reach these thresholds, you are not directly obligated