EU CSDDD: What the Due Diligence Rules Mean for Workers

The directive was amended in 2026 by Directive (EU) 2026/470 (the “Omnibus I” package), which narrowed its scope and postponed its application, so the original rules should no longer be read on their own.

EU CSDDD: What the Due Diligence Rules Mean for Workers

The European Union adopted Directive (EU) 2024/1760, known as the Corporate Sustainability Due Diligence Directive (CSDDD), to make large companies address adverse human-rights and environmental impacts connected with their activities and value chains. Its requirements are relevant to labor conditions, including those of migrant workers, but the directive does not create a new visa, residence permit, or right to work. Subsequent EU legislation has changed the original implementation schedule, so companies and workers should check the rules currently in force in the relevant country.

Key highlights and practical changes

• Who may be covered: Following the 2026 amendment, the directive applies to EU companies with more than 5,000 employees and a net worldwide turnover above €1.5 billion, and to non-EU companies with a net turnover above €1.5 billion generated in the EU. The original thresholds were 1,000 employees and €450 million. Smaller companies are not directly covered, but they may still receive information requests from covered business partners.
• What companies must do: Covered businesses are required to identify and assess actual or potential adverse impacts, take appropriate steps to prevent or mitigate potential harm, and bring actual harm to an end or minimize it. These duties can extend through a company’s chain of activities, including relevant business partners.
• Labor issues addressed: The directive links due diligence to internationally recognized human rights and labor standards. Relevant risks can include forced labor, child labor, unsafe working conditions, restrictions on workers’ freedom of association, and other serious labor-rights abuses.
• Workers and suppliers: The rules can affect people working for contractors, subcontractors, and other business partners, including migrant workers in sectors with complex supply chains. The company’s obligations depend on the risk and its connection to the business; the directive does not guarantee an individual remedy in every case. Under the amended rules, a covered company may request information from business partners only where it is necessary and proportionate, which limits the burden on smaller suppliers and recruitment agencies.
• Penalties and accountability: EU countries must provide supervisory and enforcement arrangements. Under the amended directive, the maximum fine is set at 3% of a company’s net worldwide turnover. The mandatory EU-wide civil liability regime has been removed, so liability for damage is governed by national law; the EU is to review the question by July 2031.
• Dates and transition: The “stop-the-clock” Directive (EU) 2025/794 first postponed the original deadlines. Directive (EU) 2026/470 then replaced the staggered timetable: Member States must transpose the rules by 26 July 2028, and all covered companies must apply them from 26 July 2029. National laws may still differ in detail, so check the implementing law of the relevant country.
• No visa or permit changes: Employers and workers must continue to meet the separate immigration, work-permit, and residence requirements of the country where the work is performed.

Practical impact: what workers and employers should do

For migrant and other workers

The CSDDD may strengthen attention to labor risks in business operations and supply chains, but it is not an immigration-status safeguard or a substitute for national labor-law protections. Workers should therefore distinguish between a company’s due-diligence process and their individual rights under employment, equality, health-and-safety, and immigration law.

If you suspect forced labor, recruitment-fee abuse, document retention, unsafe conditions, or unpaid wages, keep relevant records where it is safe to do so. Consider contacting a trade union, labor inspectorate, legal-aid provider, or worker-support organization in the country concerned. Do not assume that reporting a concern changes your visa status or protects you from every form of retaliation; seek confidential, country-specific advice before taking a step that could affect employment or residence.

For employers and mobility teams

Companies should map where migrant labor is used in their operations and supply chains, including labor agencies and subcontractors. A useful review should examine recruitment practices, worker-paid fees, identity-document handling, employment terms, access to grievance channels, and the risks of retaliation. Due diligence should be integrated with procurement and supplier management rather than treated as a one-time audit.

Employers should also:

• Confirm whether the company falls within the amended scope (more than 5,000 employees and over €1.5 billion turnover, or the equivalent non-EU turnover test) and track the national transposition measures due by July 2028.
• Identify which entities, suppliers, and worker groups are connected to the company’s most serious risks.
• Set up accessible reporting channels, including options workers can use without relying on a direct supervisor.
• Document follow-up, remediation, and communication with affected workers and legitimate representatives.
• Check the latest EU legislation and national transposition measures before setting compliance deadlines or updating contracts.

Main risk to monitor

A common mistake is to treat CSDDD compliance as a promise that every supplier or employer is automatically compliant—or that workers receive a new, direct route to a visa or compensation. The directive establishes corporate due-diligence duties, while the practical procedures, enforcement, and available remedies depend on the applicable EU and national rules. The directive establishes corporate due-diligence duties, while procedures, enforcement and remedies depend on the amended EU rules and the national laws that implement them from 2028–2029.