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Article

24 Feb 2026

Author:
ClientEarth,
Author:
frank bold

EU: ClientEarth and Frank Bold publish report how Omnibus I revision has reshaped CSDDD & what it means for companies and stakeholders

"How has Omnibus 1 impacted the CSDDD?", 24 February 2026

A new joint publication by ClientEarth and Frank Bold sheds light on how the Omnibus I revision has reshaped the Corporate Sustainability Due Diligence Directive (CSDDD) — and what this means for companies, regulators, and stakeholders across the EU.

The legal briefing, Sustainability Due Diligence after the Omnibus: Legal Implications for the CSDDD, provides the first legal analysis of the amended Directive. It gives an overview of the main changes and their interactions, and explains some of the more practical implications for companies.

The final Omnibus approval is not a green light for companies to step back. While the revision significantly narrows the number of companies directly in scope, the core obligations to effectively prevent and address harm across the operations and in the value chains remain. Companies that scale back their due diligence efforts are taking a gamble. The physical, reputational, and litigation risks have not shrunk — in some areas, they have grown. Robust due diligence remains the smartest risk management tool a company can have.
Julia Otten, Senior Policy Officer at Frank Bold

What are the main changes?

1. A narrower scope

One of the most significant changes is the drastic reduction in the number of companies covered... This change leaves significant parts of high-risk-sectors, such as textiles, mining, or construction out of scope...

2. Preservation of the risk-based approach

The revision kept the risk-based approach to identification. Our brief unpacks the two-step approach to identifying adverse impacts in line with international standards and the new specifications on information requests to business partners.

3. Deletion of climate transition plans

While mandatory climate transition plans were removed from the CSDDD, the obligations related to the disclosure of climate transition plans still remain under CSRD. We explain what this means.

4. Civil liability becomes less predictable

...Our analysis warns that the deletion of the overriding mandatory provision (OMP) creates significant unpredictability for victims, companies, and courts alike.

[...]

Despite the weakened framework, the CSDDD remains a landmark piece of EU legislation. Large companies active in the EU market must identify, prevent, mitigate, and remediate human rights and environmental harms across their operations and value chains.

Companies retain the opportunity to go beyond existing requirements and demonstrate leadership, especially ahead of the 2031 review.

[...]

As Member States begin transposition and companies prepare for implementation, clarity on the legal implications of the Omnibus is essential. Our joint publication provides a roadmap for navigating these challenges.

Timeline