CSDDD Due Diligence Plan Template (EU 2024/1760, Omnibus I)
Applicability test, policy, scoping exercise, in-depth assessment, prioritisation, action plans, remediation, engagement, complaints, monitoring
Mode d'emploi: Use it to plan and evidence human rights and environmental due diligence across own operations and the chain of activities. Fill the applicability test and the scoping exercise first, then write the prioritisation method before scoring. The main pitfall is an audit-only action plan that detects problems but never changes conditions for affected people.
Aperçu
Sustainability Due Diligence Plan: [Company or group name] [Plan period]
A working plan for the human rights and environmental due diligence process of a company or group: governance and policy, the scoping exercise, in-depth assessment and prioritisation of adverse impacts, prevention and corrective action plans, remediation, stakeholder engagement, the complaints procedure, monitoring and public communication. Based on the Corporate Sustainability Due Diligence Directive (Directive (EU) 2024/1760, "CSDDD") as amended by Directive (EU) 2025/794 (postponement of dates) and by the Omnibus I Directive (Directive (EU) 2026/470, published in the Official Journal on 2026-02-26, in force 2026-03-18), and on the six-step framework of the OECD Due Diligence Guidance for Responsible Business Conduct (2018) and the UN Guiding Principles on Business and Human Rights (2011). Articles are cited by number; obtain the consolidated text and your national transposition for the normative requirements. Replace every
[bracketed]value and every row marked Example. This is a document format, not legal advice; check the current official text and a qualified professional.
Document control
| Field | Value |
|---|---|
| Document ID | [DDP-YYYY] Example: DDP-2027 |
| Company and scope | [Parent and consolidated subsidiaries] Example: Quillmere Textiles N.V. and its 14 subsidiaries |
| Plan period | [YYYY to YYYY] Example: 2027 to 2029 |
| Applicability basis | [In scope from YYYY-MM-DD / voluntary] Example: In scope (EU company), national law applies from 2029-07-26; plan runs voluntarily before then |
| Lead supervisory authority | [Authority under national transposition] Example: to be designated by the Netherlands |
| Linked documents | [IDs] Example: DMA-2027, SCOC-2026, WB-POL-2026 |
| Version | [0.1] |
| Status | [Draft / In review / Approved] |
| Owner | [@head-of-sustainability] |
| Approvers/reviewers | [@general-counsel], [@chief-procurement-officer], [board sustainability committee] |
| Last updated | YYYY-MM-DD |
| Classification | [Internal / Public summary in section 11] |
| Next scheduled review | [YYYY-MM-DD] |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| Plan owner | [@name] | [Submitted] | YYYY-MM-DD |
| General counsel | [@name] | [Reviewed for legal mapping] | YYYY-MM-DD |
| Chief procurement officer | [@name] | [Accepted actions in section 6] | YYYY-MM-DD |
| Management board | [@chair] | [Approved] | YYYY-MM-DD |
| Supervisory board committee | [@chair] | [Noted] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change summary |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | Scoping exercise and risk areas drafted |
| 0.5 | YYYY-MM-DD | [@name] | Example: Prioritisation, action plans and indicators added |
| 1.0 | YYYY-MM-DD | [@name] | Example: Approved by the management board |
Contents
- Applicability, legal basis and dates
- Governance and due diligence policy
- Scoping exercise
- In-depth assessment
- Prioritisation
- Prevention and corrective action plans
- Remediation
- Stakeholder engagement
- Complaints procedure and notification mechanism
- Monitoring and indicators
- Communication and reporting
- Related regimes in other jurisdictions
- Glossary and references
- Standard and licence note
1. Applicability, legal basis and dates
State whether the company falls within the amended Article 2 and from when. The thresholds below are those in Article 4(2) of Directive (EU) 2026/470 as published in the Official Journal on 2026-02-26 (each test reads "more than"); confirm them in the consolidated text and in the national transposition, which may define employees and turnover in detail.
| Test | Threshold after Omnibus I (Article 2 as amended; check the consolidated text) | Company figure | Met? |
|---|---|---|---|
| EU company: average employees | More than 5,000 | [n] Example: 6,400 (FY2025), 6,350 (FY2026) | Example: Yes |
| EU company: net worldwide turnover | More than EUR 1.5 billion in the last financial year | [EUR] Example: EUR 1.92 billion in both years | Example: Yes |
| Non-EU company: net turnover generated in the EU | More than EUR 1.5 billion in the financial year preceding the last financial year | [EUR or n/a] Example: n/a | Example: n/a |
| Franchising or licensing route | Royalties of more than EUR 75 million and net turnover of more than EUR 275 million (worldwide for EU companies, in the EU for non-EU companies) | [EUR or n/a] Example: n/a | Example: n/a |
| Ultimate parent of a group meeting the thresholds | Consolidated figures | [Yes / No] Example: Parent is the reporting company | Example: Yes |
Key dates (check the consolidated text and national law):
| Milestone | Date |
|---|---|
| CSDDD entered into force | 2024-07-25 |
| Omnibus I Directive (EU) 2026/470 published in the Official Journal | 2026-02-26 |
| Omnibus I in force | 2026-03-18 |
| First Commission guidelines due | 2027-07-26 |
| Member State transposition deadline | 2028-07-26 |
| National measures apply | 2029-07-26 |
| Reporting under Article 16 | Financial years starting on or after 2030-01-01 |
Record the decision in one sentence. Example: "Quillmere Textiles N.V. meets both thresholds as an EU company and will be subject to the Dutch transposing law from 2029-07-26. The board decided on 2026-11-18 to run this plan from 2027 so that two monitoring cycles exist before application."
2. Governance and due diligence policy
2.1 Roles
| Role | Responsibility | Holder (Example) |
|---|---|---|
| Management board sponsor | Approves the plan and resources, receives quarterly reports | Chief operating officer |
| Due diligence lead | Runs the process, keeps this plan, chairs the working group | Head of sustainability |
| Procurement | Embeds requirements in supplier selection, contracts and purchasing practices | Chief procurement officer |
| Legal | Maps national law, drafts contractual assurances, advises on suspension | General counsel |
| Human resources | Own operations: wages, working time, health and safety, freedom of association | Chief people officer |
| Environment, health and safety | Site permits, chemicals, wastewater, emissions | EHS director |
| Internal audit | Independent assurance on the process (section 10) | Head of internal audit |
2.2 Policy content checklist
- Description of the company's approach to due diligence, including over the long term.
- Code of conduct with rules for the company, its subsidiaries and, where relevant, its business partners (see
compliance/code-of-business-conductandprocurement/supplier-code-of-conduct). - Description of the processes that put due diligence into practice, including how compliance with the code is verified.
- Commitment to consult employees and their representatives when drafting the policy.
- Review trigger: Article 7(3) asks for an update without undue delay after a significant change and a review at least every 24 months; Omnibus I did not amend Article 7, but the policy is also updated after each Article 15 assessment where appropriate. Check national law and record the cycle here: [frequency].
- Link to purchasing practices: pricing, lead times and order changes that can cause or worsen impacts at suppliers.
2.3 Due diligence cycle
The diagram shows the cycle this plan follows. Each box maps to a section of the plan and to the CSDDD articles in section 13.
3. Scoping exercise
The scoping exercise covers own operations, subsidiaries and, where linked to the chain of activities, business partners. It identifies the general areas where adverse impacts are most likely and most severe, based on information that is reasonably available. It is the basis for the in-depth assessment in section 4.
3.1 Sources used
| Source type | Examples to record | Used for |
|---|---|---|
| Internal data | Spend by supplier country and category, site list, incident logs, audit results, complaints | Exposure and history |
| Sector risk information | OECD sector guidance (garment and footwear, minerals, agriculture), ILO country reports | Sector and product risk |
| Country and context indicators | Rule of law and enforcement indicators, labour inspection capacity, water stress maps | Geographic risk |
| Stakeholder input | Trade unions, worker representatives, community representatives (section 8) | Validation of risk areas |
| Grievances | Complaints received through section 9 | Signals of actual impacts |
3.2 Risk areas identified
| Risk area ID | Area (activity, product, geography) | Value chain position | Potential impacts | Main information source |
|---|---|---|---|---|
| RA-01 (Example) | Cotton farming and ginning, country A | Upstream, Tier 3 and beyond | Forced labour, child labour | Sector guidance, import screening |
| RA-02 (Example) | Wet processing (dyeing, finishing), country B | Upstream, Tier 2 | Wastewater pollution, worker exposure to chemicals | Site audits, water stress data |
| RA-03 (Example) | Garment assembly, countries B and C | Tier 1 | Wages below living wage, excessive overtime | Payroll audits, worker survey |
| RA-04 (Example) | Building and fire safety, Tier 1 factories, country C | Tier 1 | Death or injury in structural failure or fire | Structural inspections |
| RA-05 (Example) | Own warehouses, Netherlands and Poland | Own operations | Occupational injury | Incident log |
| RA-06 (Example) | Road haulage subcontractors, EU | Downstream logistics | Driver working time, pay | Subcontractor audits |
| RA-07 (Example) | Viscose fibre production and wood pulp sourcing | Upstream, Tier 2 and 3 | Chemical emissions, deforestation | Supplier disclosures, NGO reports |
| RA-08 (Example) | Tier 1 factories, country B | Tier 1 | Restrictions on freedom of association | Union reports, complaints |
4. In-depth assessment
4.1 Information requests to business partners
The amended Article 8 limits information requests. Record for each request why it is necessary and, for partners with fewer than 5,000 employees, why the information cannot reasonably be obtained by other means.
| Request ID | Partner (size band) | Risk area | Information needed | Why necessary | Other means tried |
|---|---|---|---|---|---|
| IR-001 (Example) | Dye house B-14 (about 600 employees) | RA-02 | Effluent test results for the last 12 months | Confirm whether discharge exceeds permit limits | Public permit register checked, no results published |
| IR-002 (Example) | Fibre producer F-02 (more than 5,000 employees) | RA-07 | Pulp origin by country and certification share | Assess deforestation link | Public sustainability report covers group only |
4.2 Assessment record
For each risk area, describe the impact, the affected rights holders or environmental element, the company's involvement and the evidence. Keep evidence references so the assessment can be repeated.
| Risk area ID | Impact description | Rights holders or environment affected | Involvement | Actual or potential | Evidence |
|---|---|---|---|---|---|
| RA-01 (Example) | State-imposed forced labour in cotton harvesting reported in country A | Seasonal farm workers | Directly linked through spinning mills | Potential (no confirmed case in own supply) | Import screening, sector reports |
| RA-03 (Example) | Base wages at 74% of a credible living wage estimate in country C, overtime above legal limits in peak season | Factory workers, mostly women | Contributing through order timing | Actual | Payroll sample, worker survey |
| RA-04 (Example) | Two Tier 1 buildings with unauthorised upper floors | Workers in those buildings | Directly linked | Potential | Structural inspection reports |
5. Prioritisation
Method used in the example (write your own method before scoring):
- Severity = scale + scope + irremediable character, each scored 1 (low) to 5 (high), giving 3 to 15.
- Likelihood scored 1 (remote) to 5 (almost certain or already occurring).
- Priority score = severity x likelihood (3 to 75).
- Bands: P1 at 45 or above, P2 from 30 to 44, P3 below 30.
- Override: any risk area with severity of 13 or more is at least P2, whatever its likelihood.
| Risk area ID | Scale | Scope | Irremediable | Severity | Likelihood | Score | Priority |
|---|---|---|---|---|---|---|---|
| RA-01 (Example) | 5 | 4 | 5 | 14 | 4 | 56 | P1 |
| RA-02 (Example) | 4 | 4 | 3 | 11 | 4 | 44 | P2 |
| RA-03 (Example) | 3 | 4 | 2 | 9 | 5 | 45 | P1 |
| RA-04 (Example) | 5 | 3 | 5 | 13 | 2 | 26 | P2 (severity override) |
| RA-05 (Example) | 3 | 2 | 2 | 7 | 2 | 14 | P3 |
| RA-06 (Example) | 2 | 3 | 2 | 7 | 3 | 21 | P3 |
| RA-07 (Example) | 4 | 3 | 4 | 11 | 3 | 33 | P2 |
| RA-08 (Example) | 3 | 4 | 3 | 10 | 4 | 40 | P2 |
Lower-priority areas stay on the plan and are addressed once the higher ones are under way. Record when each P3 area will be reviewed.
6. Prevention and corrective action plans
Measures to consider, as described in Articles 10 and 11 (check the amended text):
- A prevention action plan (potential impacts) or corrective action plan (actual impacts) with timelines and indicators.
- Contractual assurances from direct business partners, cascaded where possible, with appropriate verification.
- Investments, for example in management systems or infrastructure, and changes to the company's own business plan, purchasing practices, design and distribution.
- Targeted and proportionate support for SME business partners.
- Collaboration with other companies or industry initiatives, within competition law.
- Neutralising or minimising an actual impact, with compensation where the company caused it (section 7).
- As a last resort, temporary suspension of the business relationship for the activities concerned, where law permits. After Omnibus I, termination is no longer required; before suspending, assess whether suspension could reasonably be expected to cause manifestly more severe impacts than the impact itself.
| Action ID | Risk area | Type | Measure | Owner | Start | Due | Indicator and target |
|---|---|---|---|---|---|---|---|
| ACT-001 (Example) | RA-01 | Prevention | Fibre traceability to country of origin for all cotton yarn; exclude yarn from country A unless origin is independently verified | [@cpo] | 2027-01 | 2027-12 | Share of cotton volume traced to country: 95% |
| ACT-002 (Example) | RA-03 | Correction | Pay gap programme with six Tier 1 factories; price breakdown that ring-fences labour cost; reduce late order changes | [@cpo] | 2027-02 | 2028-12 | Base wage to living wage estimate: from 74% to 90% |
| ACT-003 (Example) | RA-04 | Prevention | Independent structural assessment and remediation plan for both buildings; no orders to unsafe floors | [@ehs-director] | 2027-01 | 2027-06 | Open critical findings: 0 |
| ACT-004 (Example) | RA-02 | Prevention | Effluent treatment upgrade co-funded with two other buyers; monthly test results shared | [@ehs-director] | 2027-03 | 2028-06 | Samples within permit limits: 100% |
| ACT-005 (Example) | RA-08 | Prevention | Supplier code clause on freedom of association; joint training with the national union federation | [@cpo] | 2027-04 | 2027-12 | Factories with elected worker committee: from 9 to 20 |
| ACT-006 (Example) | RA-07 | Prevention | Pulp origin disclosure and certified share requirement for viscose suppliers | [@cpo] | 2027-06 | 2028-06 | Certified pulp share: 80% |
7. Remediation
| Case ID | Impact | Involvement | Remedy agreed with affected people | Funding | Status |
|---|---|---|---|---|---|
| REM-001 (Example) | Unpaid overtime at factory C-07 during peak season 2026 | Contributed (late order change) | Back pay for 312 workers, verified by the worker committee | Shared 60/40 between Quillmere and the supplier | Paid 2027-03-15 |
| REM-002 (Example) | Injury of a warehouse worker, Poland | Caused (own operations) | Medical costs, adapted role, safety redesign of the loading bay | Quillmere | Closed |
Remediation principles: involve the affected people in designing the remedy, do not ask them to waive legal claims as a condition, and record how the remedy was verified.
8. Stakeholder engagement
Consult relevant stakeholders when gathering information in the in-depth assessment, when developing prevention and corrective action plans, and when deciding on remediation. Other experts and civil society organisations can still inform the process even though they are no longer listed in the definition.
| Engagement ID | Stakeholder group | Stage | Method | Barriers addressed | What changed |
|---|---|---|---|---|---|
| ENG-001 (Example) | Tier 1 worker committees, country C | In-depth assessment (RA-03) | Off-site focus groups run by a local organisation | Fear of retaliation, language | Overtime pattern confirmed as linked to late orders |
| ENG-002 (Example) | National union federation, country B | Action plan (RA-08) | Joint working group | Union access to factories | ACT-005 co-designed |
| ENG-003 (Example) | Downstream community near dye house B-14 | Action plan (RA-02) | Community meeting with interpreter | Literacy | Monthly results posted in the village in the local language |
9. Complaints procedure and notification mechanism
Describe the channels, eligibility, steps, timelines and protections. Link to the internal Whistleblowing Policy (compliance/whistleblowing-policy) for own employees and explain how the two processes connect. Participating in an industry or multi-stakeholder complaints mechanism can be an option if it meets the Article 14 criteria.
| Step | Commitment (Example) |
|---|---|
| Channels | Phone line and messaging app in seven languages, web form, local partner organisations, industry mechanism |
| Acknowledgement | Within 7 days |
| Assessment of the complaint | Within 30 days, with the complainant informed of the outcome |
| Follow-up | Complainant may request a meeting with a company representative of an appropriate level |
| Protection | Confidentiality and anonymity on request; no retaliation; escalation if retaliation is reported |
Example statistics for FY2027 (fictional): 46 complaints received, 31 within the scope of this plan (67.4%), 24 of those 31 closed (77.4%), 15 complaints came through the industry mechanism (32.6% of all complaints).
10. Monitoring and indicators
| Indicator ID | Risk area | Indicator | Baseline | Target | Frequency | Source |
|---|---|---|---|---|---|---|
| KPI-01 (Example) | RA-01 | Cotton volume traced to country of origin | 38% | 95% by 2027-12 | Quarterly | Traceability platform |
| KPI-02 (Example) | RA-03 | Base wage as share of living wage estimate, six factories | 74% | 90% by 2028-12 | Semi-annual | Payroll sample |
| KPI-03 (Example) | RA-04 | Open critical structural findings | 2 | 0 by 2027-06 | Monthly | Engineer reports |
| KPI-04 (Example) | RA-02 | Effluent samples within permit limits | 71% | 100% by 2028-06 | Monthly | Accredited lab |
| KPI-05 (Example) | All | Complaints closed within 90 days | n/a | 80% | Quarterly | Section 9 log |
Monitoring cycle in the example: an internal review every 12 months for P1 and P2 areas, a full reassessment of the scoping exercise every three years, and the legal minimum as a backstop. Internal audit tests the process once in each three-year cycle.
11. Communication and reporting
| Output | Content | Channel | Date |
|---|---|---|---|
| Sustainability statement section (Example) | Process summary, material impacts, actions and indicators | Annual report (CSRD) | With the annual report |
| Public due diligence summary (Example) | Policy, risk areas, complaints statistics | Company website | Annually by 2027-06-30 |
| Report to the supervisory board (Example) | Progress on actions, KPIs, new risks | Board pack | Quarterly |
Keep the public text consistent with the Double Materiality Assessment (finance/sustainability-double-materiality-assessment) and with any climate transition plan the company publishes voluntarily or under the CSRD, since the CSDDD duty to adopt one was deleted but reporting on an existing plan can still apply.
12. Related regimes in other jurisdictions
| Jurisdiction | Instrument | Relevance | Status (checked 2026-10; verify) |
|---|---|---|---|
| EU | Regulation (EU) 2024/3015 prohibiting products made with forced labour | Product-level ban on placing on the market and export | In force 2024-12-13; main prohibition applies from 2027-12-14 |
| EU | Corporate Sustainability Reporting Directive as amended by Directive (EU) 2026/470 | Public reporting of impacts and due diligence | Scope narrowed to more than 1,000 employees and over EUR 450 million turnover |
| UK | Modern Slavery Act 2015, section 54 | Annual slavery and human trafficking statement for organisations above the turnover threshold | In force; check the current statutory guidance |
| US | Uyghur Forced Labor Prevention Act (2021) | Rebuttable presumption that goods made wholly or in part in the named region are made with forced labour | In force; check CBP guidance and entity lists |
| International | OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (2023 update) | Voluntary standard with National Contact Points | Current |
13. Glossary and references
| Term | Meaning |
|---|---|
| Adverse impact | A negative effect on human rights or the environment listed in the CSDDD Annex |
| Chain of activities | Upstream activities of business partners and certain downstream activities, as defined in the CSDDD |
| Scoping exercise | Area-based identification of where impacts are most likely and severe, replacing full mapping after Omnibus I |
| Severity | Scale, scope and irremediable character of an impact (UN Guiding Principles concept) |
| Leverage | The ability to change the wrongful practices of a business partner |
| Remediation | Restoring affected persons or the environment to the situation they would have been in |
Section to article map (CSDDD as amended; check the consolidated text): s1 Article 2; s2 Articles 5 and 7 (group level Article 6); s3 and s4 Article 8; s5 Article 9; s6 Articles 10 and 11; s7 Article 12; s8 Article 13 and the definition in Article 3; s9 Article 14; s10 Article 15; s11 Article 16; penalties Article 27; civil liability Article 29; transposition Article 37.
References:
- Directive (EU) 2024/1760 on corporate sustainability due diligence. EUR-Lex: https://eur-lex.europa.eu/eli/dir/2024/1760/oj
- Directive (EU) 2025/794 (postponement of application dates). EUR-Lex.
- Directive (EU) 2026/470 (Omnibus I), OJ 2026-02-26. EUR-Lex: https://eur-lex.europa.eu/eli/dir/2026/470/oj
- European Commission, Corporate sustainability due diligence page (status, scope and dates): https://commission.europa.eu/business-economy-euro/doing-business-eu/sustainability-due-diligence-responsible-business/corporate-sustainability-due-diligence_en
- OECD, Due Diligence Guidance for Responsible Business Conduct (2018), and OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (2023). OECD publications.
- United Nations, Guiding Principles on Business and Human Rights (2011): https://www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf
- Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market. EUR-Lex.
14. Standard and licence note
Based on Directive (EU) 2024/1760 as amended by Directives (EU) 2025/794 and 2026/470, the OECD Due Diligence Guidance for Responsible Business Conduct (2018) and the UN Guiding Principles on Business and Human Rights (2011). Articles are cited by number and paraphrased in original words; no legislative or OECD text is reproduced. The structure, guidance, scoring method and the Quillmere Textiles Group example are original; Quillmere and every figure are fictional. Status reflects the amended texts as reported by the European Commission and published summaries in October 2026; check the consolidated text on EUR-Lex and your national transposing law before use. This is a document format, not legal advice; consult a qualified professional.
Template licence: MIT.
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