After the EU Omnibus: Due Diligence as an Executive Agenda Item
CPO Path #28 CW 40 2026
Less to Collect, More to Know
EXECUTIVE PREMISE
Europe's sustainability due-diligence regime became materially narrower in 2026. For procurement, however, the more interesting change is not simply that fewer companies fall within scope.
The revised rules change how supply-chain information should be obtained: away from indiscriminate mapping and towards risk-based scoping, necessary information and deeper examination where exposure is actually concentrated (European Union, 2026).
WHY THIS MATTERS
Directive (EU) 2026/470, the "Omnibus I" package, entered into force on 18 March 2026. For CSDDD, the threshold for EU companies increased from 1,000 to more than 5,000 employees and from €450 million to more than €1.5 billion in worldwide net turnover. Non-EU groups are in scope once their net turnover generated in the EU exceeds €1.5 billion — which keeps a meaningful number of US and Asian companies inside the perimeter. The amended obligations apply from 26 July 2029, with Member States required to transpose the changes by 26 July 2028 (European Union, 2026).
CSRD was narrowed separately: the revised core threshold is more than 1,000 employees and more than €450 million net turnover, with the amended perimeter applying for financial years beginning on or after 1 January 2027 (European Union, 2026).
The moment this becomes concrete is the 2027 budget cycle, when finance asks which sustainability controls can now be scaled back. The practical question is therefore not only whether the company remains in scope. It is which controls still serve an economic, reporting or risk-management purpose once the legal perimeter has moved.
THE REAL DYNAMIC
The amended framework removes several elements that procurement and sustainability teams may previously have designed around.
The standalone CSDDD climate-transition-plan requirement was deleted. The Directive also removed the harmonised EU civil-liability regime; liability conditions now depend on national law, while the requirement of full compensation where liability exists is retained (European Union, 2026).
But due diligence itself remains — with a different operating logic.
Companies must first conduct a scoping exercise using solely reasonably available information to identify areas where adverse impacts are most likely and most severe. Detailed assessment follows in those priority areas (European Union, 2026).
This is where supplier management changes. Information may be requested from business partners only where necessary; for business partners with fewer than 5,000 employees, it may be requested only when it cannot reasonably be obtained by other means (European Union, 2026).
That weakens the case for blanket annual questionnaires as the default due-diligence architecture.
A more useful distinction may be between evidence collection and exposure management.
The legal simplification does not make the underlying supply-chain footprint disappear. CDP and BCG found that, among companies disclosing through CDP in 2023, reported supply-chain Scope 3 emissions were on average 26 times greater than emissions from direct operations. Only 15% had set a Scope 3 target, and only four in ten engaged their suppliers on climate issues (CDP & Boston Consulting Group, 2024).
The organisational implication is important. A reduced legal reporting burden can justify reducing administrative breadth. It does not automatically justify reducing management attention where environmental or human-rights exposure remains material.
WHAT STRONG LEADERS DO DIFFERENTLY
They build a one-page scope-and-sequence brief before rebuilding the programme — and bring it into the budget conversation before finance draws its own conclusions.
Step | Question | Output |
|---|---|---|
1. Perimeter | Are we inside the revised CSRD and CSDDD thresholds — and from which date? | In / out / watch, with the date that applies |
2. Evidence | What do we already know from audits, complaints, country and category risk, certifications, emissions data and existing supplier files? | A list of what no longer needs to be requested |
3. Priority | Where is adverse impact most likely or most severe — by category, country or supplier? | A short list for detailed assessment |
That sequence mirrors the risk-based logic written into the amended CSDDD itself (European Union, 2026).
Then effort can be reallocated. As an illustration: instead of sending 80 questions to 5,000 suppliers, procurement may obtain more decision value from understanding 50 suppliers deeply enough to know where intervention, contractual leverage, capability support or an alternative source is actually required.
The executive contribution is not a larger compliance programme.
It is knowing where less administration is justified — and where less attention would create exposure.
CPO PATH DIAGNOSTIC
Statement | Fully true | Partly true | Not true |
|---|---|---|---|
We have reassessed our CSRD and CSDDD scope against the 2026 thresholds. | ☐ | ☐ | ☐ |
Our supplier requests distinguish necessary information from information already available elsewhere. | ☐ | ☐ | ☐ |
Our due-diligence effort is concentrated where impact is most likely or most severe. | ☐ | ☐ | ☐ |
We have identified controls whose only justification was an obligation that no longer exists. | ☐ | ☐ | ☐ |
We can explain which supply-chain risks remain material independently of regulatory scope. | ☐ | ☐ | ☐ |
ONE-LINE VERDICT
The Omnibus reduces the obligation to collect broadly; it increases the value of knowing precisely where to look deeply.
YOUR TURN
Reply BRIEF and I will send you the scope-and-sequence brief as an editable one-pager.
QUICK WINS
This week: confirm your group's position against both revised thresholds — including the EU-turnover test for non-EU parents.
This month: pull your current supplier questionnaire and mark every question whose answer already sits in an audit, certificate or internal system.
Before the 2027 budget: name the ten suppliers where detailed assessment matters most, and table that list before anyone proposes cutting the programme wholesale.
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SOURCES
CDP & Boston Consulting Group. (2024). Scope 3 upstream: Big challenges, simple remedies. CDP. https://www.cdp.net/en/press-releases/corporates-supply-chain-scope-3-emissions-are-26-times-higher-than-their-operational-emissions
European Union. (2026). Directive (EU) 2026/470 of the European Parliament and of the Council of 24 February 2026 amending corporate sustainability reporting and due-diligence requirements. Official Journal of the European Union. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026L0470
Thank you for your time and trust,
Pascal Hecker | Editor-In-Chief, CPO Path.