Due Diligence

Due diligence means putting processes and policies in place to identify and manage negative sustainability impacts. Increasingly, this is enshrined in EU legislation such as the Corporate Sustainability Due Diligence Directive (CS3D) and the Deforestation Regulation (EUDR). We help you put processes in place to:

• manage potential negative sustainability impacts and

• comply with regulations.

Due diligence ensures risk management, strengthens ethical practices, and builds strong, resilient supplier relationships, all of which contribute to long-term business success.

CS3D: What It Covers and When It Applies

The Corporate Sustainability Due Diligence Directive, CS3D, requires large companies to identify, prevent, and address negative human rights and environmental impacts in their own operations, their subsidiaries, and across their chain of activities. Following the Omnibus I revision, which entered into force on 18 March 2026, the directive applies to EU companies with more than 5,000 employees and worldwide turnover above €1.5 billion. Non-EU companies fall in scope where their EU generated turnover exceeds €1.5 billion, with no employee threshold.

The CS3D Clock: 2027 to 2029

CS3D entered into force in July 2024, but the Omnibus revision reset its application dates. The current timeline is:

1. 26 July 2027. The European Commission publishes its main due diligence guidance, covering risk identification and prioritisation, stakeholder engagement, and model contractual clauses.

2. 26 July 2028. Member states must have transposed the directive into national law. Further Commission guidance follows, covering resource sharing and protection from retaliation.

3. 26 July 2029. Main obligations apply to in scope companies. Reporting obligations under Article 16 follow separately, for financial years starting on or after 1 January 2030.

What This Means for Your Due Diligence

We help you put processes in place across the areas CS3D due diligence covers:

1. Scoping. We identify where in your chain of activities adverse impacts are most likely and most severe.

2. In depth assessment. We assess those priority areas in detail, rather than mapping every supplier and every risk with equal depth.

3. Governance and reporting. We help you build the internal controls and public reporting CS3D requires, aligned with the fine and liability framework set out in the revised directive.

This is the same due diligence groundwork EUDR asks for, so the work you put in for one strengthens your position on the other.

EUDR: What It Covers and When It Applies

The Deforestation Regulation (EU) 2023/1115, known as EUDR, requires companies to prove that the commodities and derived products they place on the EU market are deforestation free and legally produced. It covers cattle, cocoa, coffee, palm oil, soya, rubber, and wood, including derived products such as leather, chocolate, furniture, and paper. Companies must trace these products to the plot of land where the raw material was produced and confirm no deforestation occurred there after 31 December 2020, the regulation's reference date.

The EUDR Clock: 2026 and 2027

EUDR's application date has shifted twice since the regulation entered into force in 2023. The current, legally binding timeline under Regulation (EU) 2025/2650 is:

1. 30 April 2026. The European Commission delivers a mandatory simplification review, which may still adjust obligations for smaller operators before the deadline lands.

2. 30 December 2026. Main obligations apply to large and medium operators. Due diligence statements, geolocation data, and risk assessment become mandatory for placing in scope products on the EU market.

3. 30 June 2027. Deadline for micro and small enterprises, for products other than timber, established before 2021.

How does the change affect companies?

Two changes affect who has to act. Only the operator that first places a product on the EU market must submit a due diligence statement; downstream distributors and retailers retain the reference number but no longer file their own. Companies sourcing from the EU's 140 low risk countries follow a lighter due diligence path than those sourcing from standard risk or high risk countries.

What This Means for Your Due Diligence

We help you put processes in place across the three areas EUDR due diligence covers:

1. Traceability and geolocation. We map your supply chain to the geographic coordinates of the plots where your commodities are produced.

2. Risk assessment. We assess deforestation risk and check compliance with local legislation, including human rights and labour law.

3. Mitigation and reporting. We help you build the internal controls and due diligence statements that feed into TRACES, the EU's central information system for deforestation due diligence.

This is the same groundwork CS3D and other EU due diligence legislation ask for, so the work you put in for EUDR strengthens your position across the board rather than sitting in isolation.