Understanding the CSDDD: Key Changes and Compliance Guide for EU Companies
The CSDDD (Corporate Sustainability Due Diligence Directive) has introduced new EU-wide...
By: Johannes Fiegenbaum on 9/21/25 8:06 AM
Supply chain transparency is no longer an option – it's mandatory. Since 2023, German companies with more than 3,000 employees must disclose their supply chains, and from 2024 onwards, this applies to companies with over 1,000 employees. Yet many companies struggle with implementation: Over 60% have difficulties collecting reliable data on their supply chains. Why is this important? Not only do legal requirements like the Supply Chain Due Diligence Act (LkSG) set new standards, but pressure from consumers, investors, and international standards like the EU CSRD is also growing.
What does this mean for you specifically?
The challenge? Many companies have only limited insights into their supplier chains – especially with indirect suppliers. But with clear strategies, modern technology, and close collaboration with suppliers, you can not only meet legal requirements but also build trust and secure competitive advantages.
After examining the importance of transparency in daily business operations, let's now look at the relevant legal frameworks. Legal requirements for supply chain transparency are rapidly evolving. For German companies, this means navigating a complex web of national and European regulations – with significant impacts on their business practices. These laws set new standards for responsible business conduct, building upon internationally recognized frameworks like the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.
The Supply Chain Due Diligence Act (LkSG) brings clear requirements for German companies. It has applied to larger companies since 2023, and from 2024, companies with more than 1,000 employees are also affected.
The goal of the law? To protect the rights of those who produce goods for the German market – often in regions where textiles, cocoa, fruits, or coffee are manufactured.
The law encompasses nine core obligations that companies must implement. This includes an effective risk management system that covers all relevant business processes. Additionally, a responsible person must be appointed, often in the role of a human rights officer.
Companies must conduct an annual risk analysis – both for their own business area and for direct suppliers. If the risk profile in the supply chain changes significantly, additional ad-hoc analyses are required. These analyses form the basis for a policy statement from management that summarizes the identified risks and expectations for employees and suppliers.
When risks are identified, immediate measures are necessary. These include training or contractual assurances from suppliers. If violations have already occurred or are imminent, remedial measures must be taken. Terminating business relationships is only intended as a last resort – following the motto "stay and change rather than cancel and walk away."
An internal or external complaints procedure is mandatory to enable reports of human rights or environmental risks. Indirect suppliers also fall under due diligence obligations, albeit in a reduced form.
Compliance with these obligations must be continuously documented and published in an annual report.
Violations carry severe penalties: fines of up to €8 million or 2% of global annual turnover are possible. Additionally, companies can be excluded from public tenders for up to three years.
The LkSG also references eleven internationally recognized human rights conventions that serve as benchmarks for assessment.
While the LkSG sets clear requirements for regional supply chains, the CSRD creates a European framework for sustainability reporting.
The Corporate Sustainability Reporting Directive (CSRD) is the central EU instrument for ESG disclosures and replaces the previous Non-Financial Reporting Directive (NFRD). It expands the circle of reporting-obligated companies from around 12,000 to over 50,000 and introduces standardized requirements through the European Sustainability Reporting Standards (ESRS).
The CSRD divides reporting requirements into three main categories:
Category | Description |
---|---|
ESRS E1-E5 | Environmental topics such as climate change, pollution, water resources, biodiversity, and circular economy |
ESRS S1-S4 | Social aspects, including own workforce, workers in the value chain, affected communities, and consumers |
ESRS G1 | Corporate governance |
The EU Taxonomy Regulation complements the CSRD by standardizing the classification of environmentally sustainable activities. It forms the basis for both CSRD and sustainable finance reporting. The goal is to make companies more transparent about their sustainability performance and commit them to climate protection and social standards.
Germany has not yet fully implemented the CSRD, which is why an EU infringement procedure has been initiated. Federal Finance Minister Jörg Kukies summarizes the challenges:
The various reporting systems should be synchronized so that each data point only needs to be reported once. Every CFO could tell absurd stories about how the same data must be reported multiple times. We need more fundamental regulations and less micromanagement. Additionally, European and international regulations must be aligned and interpreted consistently.
The CSRD will affect a total of 50,000 companies in the EU as well as 11,000 non-EU companies – including about 3,000 from the US. Those who fail to meet the requirements risk legal consequences, fines, damage claims, and possibly reputation loss.
After covering the legal foundations, the question arises: What specific tools can companies use to create transparency in their supply chains? Today's technology landscape offers numerous solutions – from blockchain applications to digital audit platforms. The key lies in meaningfully combining proven methods with modern technologies.
Blockchain has the potential to transform supply chain management. Through decentralized and immutable transaction records, it provides a reliable source of information for all stakeholders. Unlike centralized databases, data is stored distributed across a network of computers. This creates trust and transparency.
Some practical examples show how companies successfully use blockchain: Walmart can trace the origin of food within seconds, De Beers ensures ethically sourced diamonds, and Maersk increases efficiency in logistics.
A step-by-step approach makes sense here. Companies should first conduct pilot projects to evaluate benefits, costs, and technical requirements. It's important that stored data is accurate and current, as blockchain's added value depends on this. So-called smart contracts can automate processes – such as payments or deliveries triggered by defined conditions. Private blockchains between known partners have proven particularly effective in supply chains to ensure the origin and quality of goods.
According to forecasts, blockchain technology will generate approximately $39 billion in revenue worldwide by 2025. It also forms the foundation for other digital solutions like Lifecycle Assessments (LCA) and supplier audits.
Besides blockchain, Lifecycle Assessment (LCA) offers a structured method to evaluate the environmental impacts of products throughout their entire lifecycle. For German companies subject to CSRD (Corporate Sustainability Reporting Directive) requirements, LCA provides valuable insights into the ecological impacts of their products and services.
The method requires detailed data collection from suppliers and helps identify areas with particularly high environmental impact – so-called "hotspots." In many industries, over 80% of environmental impacts occur in the supply chain.
Compared to other approaches like Cradle-to-Cradle or circular economy, LCA is distinguished by its data-driven approach. However, a study shows that 73% of respondents have concerns about data quality in LCA. European studies also prove that food production accounts for almost half of all measured environmental impacts.
Digital tools complete the technological offering for supply chain transparency. They consolidate all relevant data and information in a central system. This is particularly important since violations of the German Supply Chain Act can result in fines of up to 2% of global annual turnover.
The acceptance rate of digital self-assessment questionnaires (SAQs) is over 80%. Christian Ritz, Partner at Hogan Lovells, explains:
Digital tools efficiently streamline the compliance process and make it easier for companies to remain compliant while navigating complex regulatory frameworks.
A survey by the Handelsblatt Research Institute shows that the majority of companies place great value on compliance with human rights and environmental standards in their supply chain.
Requirement | Measure |
---|---|
Supply chain transparency | Ensure that suppliers comply with basic human rights standards |
Risk management | Implement systematic risk management |
Reporting obligation | Document and publish violations as well as preventive measures |
Transparency projects often face challenges such as poor data quality and insufficient supplier engagement. Given strict regulations like the Supply Chain Due Diligence Act (LkSG) and the Corporate Sustainability Reporting Directive (CSRD), it's essential to address these weaknesses. In fact, up to 60% of all business initiatives fail due to poor data quality.
Successful implementation requires not only technological solutions but also clear and consistent data processes. According to the Data Warehousing Institute, erroneous, inaccurate, or incomplete data causes annual costs of over $600 billion worldwide.
The causes are diverse: inconsistent data formats, lack of standards, and insufficient data competency across different business areas. A study by NC State University confirms that these factors are primarily responsible for poor data quality.
A structured approach can provide relief. Companies should first create a detailed overview of their data supply chain to analyze data sources, processing steps, and lead times. Subsequently, it's important to capture all available data and assign each data element a central system of record (SOR).
Practical measures to improve data quality:
Data errors can not only cause high costs but also result in time-consuming manual corrections.
Besides technical integration, active engagement of supply chain partners is also crucial. A Deloitte study shows that up to 90% of a company's environmental impacts can be traced back to the supply chain.
Successful companies rely on clear standards and targeted incentives. Siemens, for example, offers suppliers training on codes of conduct and specific ESG topics like carbon tracking and sustainability audits. BBVA provides small and medium-sized enterprises with free access to multilingual online ESG courses that include checklists, templates, and recorded sessions.
Strategies for supplier engagement:
Measure | Implementation |
---|---|
Clear ESG standards | Define specific requirements, e.g., for reducing CO₂ emissions |
Measurable metrics | Establish KPIs like carbon footprint or waste management |
Contractual anchoring | Include ESG clauses in supplier contracts to ensure compliance |
Regular assessment | Require quarterly reports and third-party audits |
Stéphanie De Smedt, Head of Tech & Commercial Practice at Loyens & Loeff, emphasizes:
ESG clauses are not just a matter of compliance – they also help avoid greenwashing.
An example of standardizing such clauses is the collaboration between DocuSign and Bonterms to develop industry-wide ESG contract standards.
Incentive systems can additionally accelerate supplier acceptance. Bonus payments, preferred tenders, or project financing are effective means to achieve ESG goals together. Early supplier engagement is particularly effective, as 73% of consumers are willing to pay more for sustainable products.
Digital tools significantly facilitate the process: Over 80% of suppliers accept digital self-assessment questionnaires. Olga Episheva, Supervisor for Supplier Quality Development at Hyundai Motor Brasil, explains:
Surveys are the fastest way to efficiently design sustainability training for suppliers and measure their impact.
A combination of improved data quality and strategic supplier engagement is crucial to meet regulatory requirements and succeed long-term.
Investments in supply chain transparency not only create sustainable business value but also transform legal requirements into tangible competitive advantages. At the same time, they help minimize risks in a targeted manner and open new markets.
With transparency, companies can identify and address risks early before they have negative impacts. Especially in Germany and the EU, where the Supply Chain Due Diligence Act and other EU regulations set high standards, a proactive approach offers protection from financial damage and exclusion from public tenders.
An example of this is Nike: After the company came under criticism for working conditions at its subcontractors, it developed a comprehensive sustainability program that not only restored its reputation but was also awarded. This example shows how legal requirements can be transformed into competitive advantages.
Companies like Unilever and Walmart also benefit from greater transparency in their supply chains. Through better decisions, lower costs, and more effective risk management, they achieved significant savings. A stable and fair supply chain not only reduces the risk of disruptions but also strengthens long-term performance. Additionally, transparency creates trust among investors, who can make more informed decisions based on this foundation.
But risk minimization isn't the only crucial factor – building trust also plays a central role.
Consumers increasingly value sustainable products and are willing to pay more for them: 73% of consumers indicate they accept a premium for sustainable goods, a trend also visible among Generation Z. Products with ESG-related information grow on average 28% over five years, compared to 20% for products without such information.
Customer loyalty also benefits: 94% of consumers remain loyal to brands that provide complete transparency in their supply chain, while 39% would be willing to switch to a more transparent brand. Additionally, consumers willingly pay between 2% and 10% more for products from companies that ensure transparency in their supply chains.
Y. Karen Zheng, Associate Professor of Operations Management, explains:
"Increasing supply chain visibility always strengthens consumer trust. Furthermore, there are clear revenue potentials based on trust and greater visibility."
Another study shows that 75% of respondents view transparency as crucial for building trust between companies and consumers.
Brands like Patagonia and Chipotle successfully implement these principles. Patagonia publishes detailed information about supply chains and environmental impacts, which strengthens customer trust and loyalty. Chipotle, in turn, highlights topics like sustainable sourcing, healthy ingredients, and animal welfare in its annual sustainability report. This transparency underscores the company's values and strengthens brand value.
A 2023 study also shows that 81% of consumers worldwide expect companies to actively contribute to environmental protection. Companies that clearly and comprehensibly communicate the conditions under which their products are made enjoy consumer trust four times more often.
These examples illustrate that transparency is far more than just a legal requirement – it's a strategic decision that makes companies future-proof.
Now is the time to take action: Transparency in companies is not only a regulatory necessity but a real competitive advantage. However, the path there requires a clear, structured approach that goes beyond mere compliance.
Start with a thorough assessment. Analyze your entire supply chain and identify both direct and indirect suppliers. It's crucial to review your data collection and identify potential weaknesses. This analysis forms the foundation for all further steps toward greater transparency.
Building on this, the next step is the targeted use of modern technologies. Rely on the right digital tools. Blockchain solutions for immutable traceability, LCA software for evaluating environmental impacts, and platforms for supplier audits are part of the necessary infrastructure. Make sure to choose tools that integrate seamlessly into your existing systems and enable standardized data exchange.
Another key to success lies in collaboration with other companies. Initiatives like the LkSG Initiative Industry and Trade by GS1 Germany show how valuable industry-specific cooperations can be. Since January 2023, more than 50 companies have been working together on practical solutions, including a unified questionnaire model 2.0 that can already be integrated into IT systems. Such approaches demonstrate how standardization and collaboration lead to tangible results.
View your suppliers as partners. Transparency doesn't emerge through control alone, but through continuous dialogue and joint development. Support your suppliers with training, share best practices, and create incentives for trustful collaboration.
Stay flexible regarding regulatory changes. With the upcoming introduction of the EU Corporate Sustainability Due Diligence Directive (CSDDD) and adjustments to CSRD reporting obligations – which exempt many companies from the requirement – it's crucial to design your systems to be adaptable. Flexible compliance frameworks that can quickly adjust to new requirements are key here.
Regular reviews are essential to ensure your measures are effective. Focus on measurable success. Track metrics like the percentage of suppliers covered by due diligence, the number of risks identified and resolved, or improvements in supplier compliance. These KPIs not only support your reporting but also demonstrate the business value of your transparency strategy.
Transparency is more than an obligation – it's an investment in the future. Companies that consistently pursue this path master regulatory challenges, gain customer trust, open new market opportunities, and position themselves as responsible actors. The first step? Viewing transparency not as a cost factor, but as a strategic advantage.
Companies have the opportunity to significantly improve data quality in their supply chains through the use of modern technologies like blockchain. This technology ensures that information remains transparent, cannot be manipulated, and is always traceable – a real benefit for traceability.
Furthermore, regular supplier audits play a central role. They help ensure the accuracy and reliability of collected data. Combined with well-organized data management, inconsistencies can be effectively reduced and data quality maintained sustainably.
Such measures enable companies not only to comply with legal requirements but also to strengthen the trust of their customers and business partners – an important aspect in an increasingly data-driven world.
The introduction of blockchain technology in supply chains offers the possibility to document transactions transparently and immutably in real-time. This enables companies to significantly improve traceability, identify potential risks early, and reliably ensure compliance with environmental and social standards.
Especially in complex supply chains with numerous actors, blockchain creates trust by providing a verifiable and tamper-proof data foundation. For this technology to reach its full potential, it's crucial that all stakeholders along the supply chain are involved and work uniformly with the technology. This enables smooth collaboration and strengthens transparency in the long term.
Actively involving your suppliers in implementing ESG standards offers you numerous benefits. It creates more transparency in the supply chain and minimizes risks – which significantly facilitates compliance with legal requirements like the EU Taxonomy and CSRD. At the same time, it strengthens the trust of your customers and investors, improves your company's reputation, and gives you a competitive edge through sustainable procurement strategies.
Furthermore, considering ESG criteria in supplier selection contributes to sustainable value creation and promotes long-term partnerships. This not only makes the entire supply chain more resilient but also creates a more stable foundation for your business. Companies that actively involve their suppliers position themselves as pioneers in sustainable business practices and thus secure a clear advantage in an increasingly regulated market environment.
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