๐Ÿ‡ช๐Ÿ‡บJurisdiction Guide

Supplying to EU companies? Here's what CSRD, CSDDD, and the EU Taxonomy mean for your business.

The EU's Corporate Sustainability Reporting Directive (CSRD) is the most far-reaching sustainability reporting law in the world. It requires large EU companies to report on their entire supply chain โ€” including non-EU suppliers. If you sell to EU buyers, their compliance depends on your data.

Key regulations in the EU

CSRD โ€” Corporate Sustainability Reporting Directive

In Force
Phase 1 (FY 2024): Large EU public-interest entities (>500 employees) โ€” reports due 2025. Phase 2 (FY 2025): Large EU companies (>250 employees or >โ‚ฌ40m turnover) โ€” reports due 2026.

CSRD requires large EU companies to report on environmental, social, and governance topics under the European Sustainability Reporting Standards (ESRS). Crucially, it requires disclosure of value chain data โ€” meaning your EU buyers will need your sustainability data to complete their own reports. The VSME standard is available for SMEs in supply chains.

CSDDD โ€” Corporate Sustainability Due Diligence Directive

Upcoming
CSDDD transposition deadline: July 26, 2028. Compliance required July 2029. Phase 1 (2029): >5,000 employees and โ‚ฌ1.5bn turnover. Phase 2 (2029): >3,000 employees and โ‚ฌ900m turnover. Phase 3 (2029): >1,000 employees and โ‚ฌ450m turnover.

CSDDD requires large EU companies to conduct due diligence on their entire supply chain for human rights and environmental risks. Unlike CSRD (reporting), CSDDD requires action โ€” companies must identify, prevent, and remediate adverse impacts. Suppliers will receive due diligence questionnaires and may be required to sign codes of conduct.

EU Taxonomy Regulation

In Force
In force. Reporting obligations phased from 2022.

The EU Taxonomy classifies economic activities as environmentally sustainable. Large EU companies must disclose what proportion of their revenue, capex, and opex is taxonomy-aligned. Suppliers may be asked to provide data on the environmental characteristics of their products and processes.

CBAM โ€” Carbon Border Adjustment Mechanism

In Force
Transitional phase: October 2023 โ€“ December 2025. Full implementation: January 2026.

CBAM puts a carbon price on imports of certain goods (steel, aluminium, cement, fertilisers, electricity, hydrogen) from outside the EU. Importers must report the embedded carbon content of their products. If you export these goods to the EU, you will need to provide verified carbon data.

GDPR โ€” General Data Protection Regulation

In Force
In force since 25 May 2018. Applies to all organisations processing EU personal data.

Under GDPR Article 33, organisations must notify their national supervisory authority within 72 hours of becoming aware of a personal data breach that is likely to result in risk to individuals. If the breach is likely to result in high risk to individuals, affected persons must also be notified without undue delay (Article 34). Fines can reach โ‚ฌ20 million or 4% of global annual turnover. GDPR applies to any organisation processing personal data of EU residents, regardless of where the organisation is based. Suppliers handling EU customer or employee data must comply.

NIS2 Directive โ€” Network and Information Security

In Force
NIS2 Directive in force from October 2024. EU member states required to transpose by October 17, 2024.

NIS2 significantly expands the scope of EU cybersecurity obligations. Covered entities in 18 critical sectors must implement risk management measures and report significant cyber incidents to their national CSIRT within 24 hours (early warning) and 72 hours (full notification). NIS2 explicitly includes supply chain security: covered entities must assess the cybersecurity practices of their suppliers and service providers. This creates direct obligations for suppliers to EU critical infrastructure operators. Fines for essential entities can reach โ‚ฌ10 million or 2% of global annual turnover.

What this means for you as a supplier

EU buyers in Phase 1 and Phase 2 of CSRD (large companies with >250 employees) are legally required to report on their value chain. They will use the VSME standard to request data from their SME suppliers. Expect questionnaires covering your energy use, GHG emissions, waste, water, and social policies. The earlier you prepare, the more competitive you will be as a supplier.

Key dates

2025

Phase 1 CSRD reports published (FY 2024 data) โ€” buyers start requesting supplier data

2026

Phase 2 CSRD reports due (FY 2025 data) โ€” significantly more buyers in scope

January 2026

CBAM full implementation โ€” carbon data required for covered goods

July 2029

CSDDD Phase 1 โ€” largest companies must conduct supply chain due diligence

2027

Phase 3 CSRD โ€” listed SMEs in scope

2029

Phase 4 CSRD โ€” non-EU companies with >โ‚ฌ150m EU net turnover in scope

Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change โ€” verify current requirements with a qualified adviser.

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