Your Belgian customer chose to send you this questionnaire. That distinction matters.
Belgium does not yet have a national duty of vigilance law. Belgian companies are not legally required to assess their suppliers today. They are doing it anyway — because they helped write the CSDDD, lobbied for it, and then decided not to wait for their own government to transpose it. Belgian buyers including AB InBev, Solvay, UCB, Bekaert, and Umicore are applying CSDDD standards to their supply chains as a deliberate business decision. That makes their questionnaire different from a German LkSG request or a UK Modern Slavery Act statement: there is no penalty driving it. They are asking because they chose to.
Key regulations in Belgium — CSDDD & Duty of Vigilance Supplier Guide
Belgium — Proposed Duty of Vigilance and Care in Value Chains
Belgium's proposed duty of vigilance law would require companies established or active in Belgium to identify, prevent, mitigate, and cease human rights, labour rights, and environmental harm throughout their full value chain. The obligation would be proportionate to company size. Large companies (over 250 employees, over 50m EUR turnover or over 43m EUR balance sheet) would face full due diligence and reporting obligations. SMEs in high-risk sectors — including minerals and metals (3TG), agricultural products, clothing, footwear, and extractive industries — would face additional obligations. Penalties include criminal fines up to 1.6 million EUR and exclusion from public procurement contracts.
CSDDD — EU Corporate Sustainability Due Diligence Directive
Belgium was the EU Council Presidency country that finalised the CSDDD in May 2024. Belgian buyers are therefore among the most prepared for CSDDD compliance in Europe. The directive requires covered companies to conduct human rights and environmental due diligence across their full value chain, establish grievance mechanisms, and adopt a climate transition plan. Belgian buyers are already applying these standards voluntarily — their supplier questionnaires reflect CSDDD requirements now, ahead of the formal transposition deadline.
CSRD — EU Corporate Sustainability Reporting Directive
Belgian companies in scope for CSRD must report on their supply chain's environmental and social impacts. This creates an immediate data demand on suppliers — Belgian buyers need your emissions data, social metrics, and governance information for their own mandatory CSRD reports. If you supply a Belgian company with over 250 employees, expect data requests now.
Belgian GDPR (AVG/RGPD) & CCB Cyber Obligations
Belgium implements GDPR (known as AVG/RGPD) with 72-hour breach notification to the Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données, GBA/APD). The GBA is an active enforcer. Belgium's NIS2 implementation requires essential and important entities to report significant incidents to the Centre for Cybersecurity Belgium (CCB) within 24 hours (initial notification) and 72 hours (detailed report). The CCB coordinates national cyber incident response and issues binding cybersecurity guidance. Belgium hosts NATO and EU institutions, making it a high-value target for state-sponsored cyber threats. Suppliers processing Belgian customer data must align incident response to the GBA 72-hour GDPR window and CCB NIS2 reporting requirements.
What this means for you as a supplier
You are not directly regulated by Belgian law. But your Belgian buyer is preparing for both CSDDD and their own national duty of vigilance law — and they helped write the CSDDD, so they are ahead of most EU buyers in applying it. A non-response or weak response to their questionnaire means they cannot demonstrate adequate due diligence in their value chain. Belgian buyers are also subject to CSRD reporting requirements now, which means your emissions and social data is needed for their own mandatory reports. Your compliance evidence serves two purposes: their CSDDD preparation and their CSRD report.
Key dates
April 2021
Belgium introduces national duty of vigilance proposal — not yet passed
January 2024
Belgium takes EU Council Presidency — drives CSDDD finalisation
May 2024
CSDDD formally adopted — Belgian buyers immediately begin CSDDD-aligned supply chain assessments
FY 2024 / 2025
CSRD reporting begins for large Belgian companies — supplier data requests active now
July 26, 2028
CSDDD transposition deadline for EU member states (delayed from original 2026)
July 2029
CSDDD compliance required — Belgian companies with over 1,000 employees and €450m turnover in scope
2028–2029
Expected window for Belgian national duty of vigilance law to enter into force alongside CSDDD
No law requiring this — they chose to do it anyway
This is unusual. Most supply chain questionnaires are driven by a legal obligation on the buyer — LkSG in Germany, the Åpenhetsloven in Norway, the Loi de Vigilance in France. Belgian buyers are not legally required to assess their suppliers today. Belgium's national duty of vigilance law is still a proposal. The CSDDD does not formally apply until July 2029 (transposition deadline July 26, 2028). Belgian companies lobbied for the CSDDD, helped finalise it during their EU Council Presidency in 2024, and then applied its standards immediately — before the law required it. If your Belgian buyer is asking you for compliance evidence, it is a choice, not a mandate. That tells you something about how seriously they take it.
Which Belgian companies are preparing for due diligence
Belgian companies in scope for CSDDD (compliance from July 2029; transposition deadline July 26, 2028) are already conducting supply chain assessments. Belgian companies in scope for CSRD (over 250 employees, already active) are requesting supplier data now. The proposed national law would extend obligations to all companies established or active in Belgium, with additional requirements for SMEs in high-risk sectors.
- • Belgian companies with over 250 employees
- • Reporting FY 2024 / 2025 data
- • Requesting supplier emissions and social data now
- • AB InBev, Solvay, UCB, Bekaert, Umicore in scope
- • Belgian companies with over 5,000 employees (Phase 1)
- • Full value chain due diligence required
- • Grievance mechanisms and transition plans
- • SMEs in high-risk sectors face additional obligations
What your questionnaire will cover
Belgian buyer questionnaires combine CSRD data requirements (emissions, social metrics) with CSDDD due diligence questions (human rights, labour rights, environment). Expect both.
Penalties under the proposed Belgian law and CSDDD
These penalties apply to your buyer — but your buyer's ability to comply depends on your cooperation.
| Framework | Penalty | Enforcer |
|---|---|---|
| Belgian national law (proposed) | Criminal fines up to 1.6 million EUR; exclusion from public procurement | Belgian courts / regulator |
| Belgian national law (proposed) | Level 5 criminal sanction: fine 250–100,000 EUR and/or imprisonment up to 1 year | Public Prosecutor |
| CSDDD | Fines up to 5% of global net turnover | National supervisory authority |
| CSDDD | Civil liability for damages throughout value chain | Belgian courts |
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
Received a CSDDD or duty of care questionnaire?
ESG Stress Free guides Belgian suppliers through CSDDD and duty of vigilance compliance requirements.