CSDDD
CSRD
EC
Council
EP
Remove provisions regarding transition plan for climate change
No change
>3,000 employees and >€450M revenue
Transition plan
Maintain obligation to adopt with no reference to implementation
>€1.5B revenue
>5,000 employees and >€1.5B revenue
Non-EU Scope
Maintain obligation to adopt but remove requirement to put transition plan into effect
No change
No change
EU Scope
EC
Council
EP
Cap extent of information requests to companies with <3,000 employees; make 3-year transition unlimited
Non-EU parent with in-scope sub or branch >€450M revenue
>3,000 employees and >€450M revenue
Value Chain
Same as EC, plus if requests go beyond, companies have right to decline providing information
Same as EC
>1,000 employees and >€450M revenue
Non-EU Scope
Cap extent of information requests to companies with ≤1,000 employees
>€450M revenue and large sub or branch >€50M revenue
>1,000 employees and either >€50M revenue or >€25M assets
EU Scope
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CSDDD
CSRD
As adopted
As provisionally amended
Exemption
Group exemption would also be available for large, listed PIEs.
A separate exemption would apply to certain EU and non-EU financial holding undertakings.
A 12-month transition period for newly acquired subsidiaries.
A transition exemption would be available for companies that had to start reporting from financial year 2024 (Wave 1 companies) falling out of scope for 2025 and 2026.
> €450M revenue generated in the EU and at least one EU subsidiary or branch with > €200M revenue
> 1,000 employees and > €450M revenue
Non-EU Scope
Subsidiary exempt from reporting if included in a parent’s reporting. Exemption is not available for large, listed PIEs.
> €150M revenue in the EU and at least (1) one EU subsidiary that meets CSRD scoping; or (2) one EU branch with > €40M revenue.
> 1,000 employees and either > €50M revenue or > €25M assets
EU Scope
Value chain
Reporting must address material impacts, risks and opportunities across the value chain for which companies may need to request data from value‑chain partners.
Assurance standards
Value‑chain cap would limit requests from companies with ≤ 1,000 employees to information specified in the standards for voluntary use.
Maintains the limited assurance requirement but removes the requirement to move to reasonable assurance over time. The EC has until July 1 2027 to adopt limited assurance standards.
Limited assurance required over the entire sustainability report, with the intent of moving to reasonable assurance in time. The European Commission (EC) to adopt limited assurance standards by October 2026.
As adopted
As provisionally amended
Would eliminate the uniform EU-level civil liability regime, allowing Member States to maintain or adopt their own liability regimes.
Would remove requirement to adopt a transition plan
Companies would take a risk-based approach to identify actual and potential adverse impacts most likely to occur and most severe. Where adverse impacts are identified, they would prioritize assessing the impacts on their direct business partners.
> €1.5B revenue generated in the EU; or > €275M revenue in the EU and > €75M royalties in the EU from franchising or licensing agreements in the EU.
> 5,000 employees and > €1.5B revenue; or > €275M revenue and > €75M royalties from franchising or licensing agreements in the EU.
Introduces an EU-level civil liability regime - Member States are required to ensure through national law that a company can be held liable for damage caused to a natural or legal person due to the company’s failure (whether intentionally or negligently) to prevent or mitigate potential adverse impacts, or end or minimize the extent of actual adverse impacts.
Adopt, put into effect and update a transition plan.
Identify actual and potential adverse human rights and environmental impacts, with respect to their own operations, the operations of their subsidiaries, and operations carried out by direct and indirect business partners throughout their value chain.
> €450M revenue generated in the EU; or > €80M revenue in the EU and > €22.5M royalties in the EU from franchising or licensing agreements in the EU.
> 1,000 employees and > €450M revenue; or > €80M revenue and > €22.5M royalties from franchising or licensing agreements in the EU.
Civil liability
Climate transition plan
Extent of due diligence obligations
Non-EU Scope
EU Scope