EU: Corporate Sustainability Due Diligence Directive (CSDDD/CS3D) Transposition Tracker

There have been no developments in Austria.

Contact: Jan Lehký at Kinstellar. 

Last updated 26 May 2026.

There have been no developments in Belgium.

Contacts: Tom Cobbaert and Guillaume Croisant. 

Last updated 15 May 2026.

There have been no developments in Bulgaria. There is no indication as to when the transposition process might start, and no draft legislation or other official documents relating to the process have been published. The only publicly available information concerns a session of a committee with the Bulgarian Ministry of Labour, during which the new obligations under CS3D were discussed in general terms. However, no specific implementation targets or timeline were indicated.

Contact: Jan Lehký at Kinstellar. 

Last updated 26 May 2026.

There have been no developments in Croatia. There is no official information available as to when the implementation process is expected to start.

Contact: Jan Lehký at Kinstellar. 

Last updated 26 May 2026.

CS3D transposition work was originally started by the previous government; however, the legislative process was not completed before the end of its term. The current government assumed office in December 2025, and its legislative work plan for 2026 does not include any CS3D transposition legislation. According to the Czech Government’s legislative work plan for 2027–2028, transposition is currently planned for 2027, with the draft proposal expected to be submitted to the Government in Q3 2027.

Contact: Jan Lehký at Kinstellar. 

Last updated 26 May 2026.

The Ministry of Justice and Digital Affairs of Estonia is still at an early stage of planning to transpose the CS3D, and no exact solutions have been agreed upon. However, Estonia is also considering transposing the directive into a separate law. The reason for this is that there is no legislation in Estonia that could be supplemented in order to transpose the content of the duty of due diligence for entities into Estonian legislation.

Contacts: Elina Lumiste and Annika Kask at Sorainen. 

Last updated 29 May 2026.

There have been no developments in France.

However, it is worth noting the following French case law regarding the French Duty of Vigilance Law:

• On 17 June 2025, the Paris Court of Appeal issued its first decision on the merits based on the French Duty of Vigilance Law (FDVL). The Court upheld the judgment ordering the French state-owned postal company (La Poste) to revise its vigilance plan. For more information, see our blog post.
• Several environmental protection associations and the Paris City Council (Mairie de Paris) have brought proceedings against the oil group TotalEnergies. The claimant parties accuse TotalEnergies of having breached its duty of vigilance regarding environmental risks and are seeking an order to halt its new oil and gas projects. The parties were heard before the Paris Judicial Court on 19 February 2026 and a judgment is expected before summer 2026.
• On 12 March 2026, the Paris Judicial Court, for the first time, found a French parent company liable under the duty of vigilance in a case involving former employees of a foreign subsidiary which, at the time of the events, was 51 per cent owned by the Rocher group. The group was ordered to pay each of nine employees of its former Turkish subsidiary EUR 8,000 and EUR 40,000 to their trade union, Petrol-Is. The court found the parent company at fault for excluding its subsidiaries from the scope of its risk mapping, and established a causal link with the harm suffered by employees who had been dismissed because of their trade union membership.

Contacts: Ngoc-Hong Ma, Eleonore Hannezo, Jean-Charles Jais, and Emilie Rochat. 

Last updated 19 May 2026.

There have been developments in Germany.

It is worth noting that in September 2025, the German government adopted a bill with proposals to delete reporting obligations and reduce penalties under the German Supply Chain Due Diligence Act. For more information, see our blog post.

Contacts: Dr.Julia Grothaus and Miriam Erb. 

Last updated 18 May 2026.

There have been no developments in Greece.

Contacts: Michael Tsibris, Effie Papakonstantinou and Giannis Koumettis at Souriadakis Tsibris. 

Last updated 18 May 2026.

As of May 2026, CS3D has not yet been implemented in Hungary. There is currently no information available regarding the expected timing of implementation, or whether it will be carried out through amendments to existing legislation, such as Act CVIII of 2023, or through the adoption of new legislation. Pursuant to Government Decree 90/2026 (V.13.), the Minister of Economy and Energy is responsible for economic development matters. It is therefore assumed that the Minister of Economy and Energy will also be responsible for preparing the legislation relating to the transposition of CS3D.

Contact: Jan Lehký at Kinstellar. 

Last updated 25 May 2026.

In response to a parliamentary question on 30 April 2026, Niamh Smyth, Minister of State at the Department of Enterprise, Tourism and Employment, noted that the department is working to ensure transposition by the July 2028 deadline. It is not clear at this stage whether draft legislation will be published in advance for consultation.

Contacts: Jill Shaw and Patrick Brandt at A&L Goodbody LLP. 

Last updated 18 May 2026.

The European Delegation Law 2025 (Law no. 36 17 March 2026 Legge di delegazione europea 2025) which entered into force on 9 April 2026 delegates to the Italian Government the transposition of EU directives and the implementation of other EU legal acts adopted between June 2024 and September 2025, including the CS3D. The Government must exercise that delegation no later than 4 months before the transposition deadline, i.e. by approximately 26 March 2028 and take into account all EU-level amendments to the CS3D, including the Stop-the-Clock Directive and the Omnibus I Directive. 

Contacts: Anna Ferraresso and Samuele Manfredo Pio. 

Last updated 15 May 2026.

Transposition of CS3D was paused until further clarity from the Omnibus process.  No draft legislation has been formally published or submitted for parliamentary consideration.

Contact: Agita Sprude at Sorainen. 

Last updated 29 May 2026.

There have been no developments in Lithuania.

Contact:: Vitalija Impolevičienė at Sorainen. 

Last updated: 21 May 2025.

No draft law has been published regarding the transposition of the CS3D. However, a motion no. 4778 was approved by the Luxembourg parliament (Chambre des Députés) for the purpose of inviting the government to ensure, in the context of the transposition of the CS3D, that (i) the supervising authority enjoys organisational, administrative and financial independence from the government and (ii) the designated supervisory authority shall develop sufficient expertise in the fields of human rights and environmental protection.

It is also interesting to note that a draft law no. 8217 was introduced in May 2023 at the initiative of two members of parliament to introduce under Luxembourg law a duty of care for undertakings regarding sustainability. Its content is, to some extent, inspired from the CS3D which was not final at the time and should not be considered as a transposition of the CS3D. The parliamentary process is in progress with respect to this draft law but it remains to be seen what will come of it once the Luxembourg initiates the transposition process of CS3D.

Contacts: Remy Bonneau and Marie Arnaud-Rio

Last updated: 11 June 2026.

In relation to the ‘original’ CS3D (i.e., prior to the Omnibus I Directive), the Dutch legislator published a draft implementation bill for consultation (Wetsvoorstel internationaal verantwoord ondernemen (the“WIVO”). The WIVO was, however, not adopted and the implementation process did not progress while the Omnibus I Directive was under development at EU level. 

Now that the Omnibus I Directive (with its delayed implementation date) has been adopted, the legislator confirmed on 12 March 2026 that a revised draft WIVO is envisaged to be published in 2027. It is expected that this revised draft WIVO will first be shared with the Dutch Council of State (Raad van State) for advisory purposes, following which it will be submitted to Parliament, specifically to the Dutch House of Representatives and subsequently to the Dutch Senate. Both chambers of parliament must vote in favor of adopting the WIVO. 

Contacts: Gerad Meijer, Daniella Strik and Bas van Niekerk, and Georgios Fasfalis. 

Last updated: 18 May 2026.

Certain developments around the implementation of the CS3D have been noted in Poland, in particular that the Ministry of Development and Technology (the "MDT") has officially announced that it is already working on the drafting of the implementing legislation. 

Moreover:

• On 24 March 2026, the MDT launched a call for members of the working group on the CS3D and corporate due diligence in the areas of human rights and environmental protection in business (as part of the Task Force for Supporting Sustainable Business Development). The working group will focus on the transposition of the CS3D into national law. Experts will examine specific provisions of the Directive and other related legal acts that will require amendment in connection with the implementation of the CS3D. The working group will also discuss the designation of a supervisory authority and consider the potential coordination of its competences with other supervisory bodies.
• Between 11 September 2025 and 31 October 2025, the MDT conducted the CS3D Pre-Consultation, inviting interested parties (businesses, non-governmental organisations and industry bodies) to share their views on the transposition of the provisions of the CS3D into Polish law by responding to a questionnaire (available in Polish only).

However, no such draft implementation has been published yet. 

Contact: Wojciech Kobylinski at Wardynski.

 Last updated 19 May 2026.

The transposition process has not been initiated, and there is no forecast for it to begin in the near future.

Contacts: Vera Ferreira de Lima, Mariana Serra Baptista and Nuno Devesa Neto.

Last updated 1 June 2026.

There have been no developments in Romania. 

Romanian authorities remain in an assessment and preparatory phase regarding the institutional setup, with no further public developments. Under the transposition plan for EU directives in Romania, it was stated that CS3D is being assessed in terms of institutional competence for transposition and schedule.

Contact: Jan Lehký at Kinstellar. 

Last updated 25 May 2026.

There have been no developments in Slovakia. 

Contact: Jan Lehký at Kinstellar. 

Last updated 25 May 2026.

There have been no developments in Spain.

(The CSRD is still waiting to be incorporated first.)

Contacts: Antonio Camara and Mercedes Agreda. 

Last updated 15 May 2026.

On 13 December 2024, the government appointed a special investigator to analyse how the CS3D should be implemented in Sweden. The investigator was scheduled to publish the report on 16 December 2025. 

The deadline for the investigation has now been extended twice, most recently to August 2026, and the scope of the investigation has been expanded to reflect the changes at EU level under the Omnibus I package. Sweden remains in the investigation phase and no bill or legislative proposal has been published to date.

Contacts: Rasmus Kindlund, Saku Sainio and Adam Wahlén Winqvist.  

Last updated 18 May 2026.