Next 12 months
CSRD
Corporate Sustainability Reporting Directive
Revised ESRS enter into force 10 November 2026. Member States transpose by 19 March 2027. Wave 2 reports on FY2027, published in 2028.
Where it standsAmended by Omnibus I (Directive (EU) 2026/470), in force since 18 March 2026. Now for companies with more than 1,000 employees and more than €450m turnover. Revised ESRS published 21 September 2026, with over 60% fewer mandatory datapoints.
Source What it means for your team
Re-check whether you are in scope, plan your next report on the revised ESRS and cap supplier data requests at the Voluntary Standard (VSME).
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Further ahead
CSDDD
Corporate Sustainability Due Diligence Directive
Transposition by 26 July 2028. Compliance from 26 July 2029.
Where it standsAmended by Omnibus I. Scope narrowed to companies with more than 5,000 employees and €1.5bn turnover. The climate transition plan duty and EU-wide civil liability are removed.
Source What it means for your team
Only the largest groups are in scope, but customers in scope will push due diligence questions down their supply chain. Build a proportionate process now.
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Applies now
EU Taxonomy
Taxonomy reporting simplification
Applies to FY2026 reporting.
Where it standsDelegated Regulation (EU) 2026/73 applies from 1 January 2026. Activities below 10% of a KPI can be left out and templates are much shorter.
Source What it means for your team
Run the 10% materiality screen on your Taxonomy KPIs and drop activities that are not material.
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Next 12 months
EUDR
EU Deforestation Regulation
30 December 2026 for large and medium companies. 30 June 2027 for micro and small companies.
Where it standsAmended by Regulation (EU) 2025/2650. Downstream operators no longer file their own due diligence statement, and small primary operators get a simplified declaration.
Source What it means for your team
Finish mapping cattle, cocoa, coffee, palm oil, rubber, soy and wood in your supply chain and collect geolocation data from suppliers now.
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Applies now
CBAM
Carbon Border Adjustment Mechanism
Certificate sales start 1 February 2027. First annual declaration for 2026 imports due 30 September 2027.
Where it standsDefinitive period since 1 January 2026. Importers above 50 tonnes a year need authorised CBAM declarant status.
Source What it means for your team
Check whether you pass the 50 tonne threshold, get actual emissions data from suppliers and budget for 2026 certificates.
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Applies now
PPWR
Packaging and Packaging Waste Regulation
Harmonised labelling follows later, as the implementing acts are delayed. Recyclability grades and recycled content targets from 2030.
Where it standsRegulation (EU) 2025/40 applies since 12 August 2026, including the EU Declaration of Conformity, technical documentation and PFAS limits in food-contact packaging.
Source What it means for your team
Make sure you have a Declaration of Conformity and technical file for all packaging, and start recyclability assessments for 2030.
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Applies now
ESPR and DPP
Ecodesign for Sustainable Products and the Digital Product Passport
Disclosure of discarded products from 2 March 2027. First Digital Product Passports expected around 2028 to 2029.
Where it standsLarge companies may no longer destroy unsold apparel, clothing accessories and footwear since 19 July 2026. Product-specific ecodesign rules are still being drafted.
Source What it means for your team
Large apparel companies must comply now. For most others the Digital Product Passport is a 2028 topic, so start structuring product data.
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Applies now
EmpCo
Empowering Consumers for the Green Transition
In force now. National enforcement is starting.
Where it standsApplies since 27 September 2026. Bans generic claims such as "eco" or "green" without proof, product-level "climate neutral" claims based on offsetting and uncertified sustainability labels.
Source What it means for your team
Audit consumer-facing claims and labels now and remove anything generic or based on offsetting.
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Not adopted
Green Claims Directive
Proposed rules for verifying environmental claims
No date.
Where it standsNot adopted. The Commission signalled in June 2025 that it intended to withdraw the proposal.
Source What it means for your team
EmpCo and national consumer law apply. Substantiate every claim as if verification were required.
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Next 12 months
Battery Regulation
EU Battery Regulation
Battery passport from 18 February 2027. Supply chain due diligence from 18 August 2027.
Where it standsIn force, with several obligations postponed.
Source What it means for your team
If you make or import batteries, prepare the passport and due diligence on cobalt, lithium, nickel and graphite.
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Next 12 months
Pay Transparency
EU Pay Transparency Directive
Employers with 150 or more employees report their gender pay gap by 7 June 2027.
Where it standsTransposition deadline was 7 June 2026. Several Member States are late.
Source What it means for your team
Collect 2026 pay data now. It also feeds ESRS S1 reporting.
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Further ahead
Forced Labour Regulation
Ban on products made with forced labour
Applies from 14 December 2027.
Where it standsAdopted and in force. Commission guidelines published 26 June 2026.
Source What it means for your team
Map high-risk suppliers and regions and prepare evidence files you can share quickly if authorities ask.
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Not adopted
SFDR 2.0
Sustainable Finance Disclosure Regulation review
Final text not expected before 2027.
Where it standsProposed in November 2025. Council and Parliament positions agreed, negotiations ongoing.
Source What it means for your team
No change for corporates yet. Expect continued data requests from investors and banks on transition plans.
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General information, not legal advice. Dates and thresholds can change and national transposition can differ, so check the source before you act.
