CSRD, CSDDD and supply chain laws after the Omnibus: what still applies

Short answer: After Omnibus I (Directive (EU) 2026/470, in force since mid-March 2026), the CSRD requires sustainability reporting only from companies with more than 1,000 employees and net turnover above EUR 450 million; Member States must transpose this by 19 March 2027. The CSDDD now covers only companies with more than 5,000 employees and turnover above EUR 1.5 billion and will apply from 26 July 2029. In Germany, the due diligence duties of the Supply Chain Act (LkSG) still apply to companies with 1,000 or more employees, while the reporting duty is suspended. In Switzerland, the reporting and due diligence duties in the Code of Obligations (OR) are unchanged.

This overview is for heads of compliance, general counsel and sustainability and procurement leads in Germany and Switzerland. It explains which Omnibus changes apply to the CSRD, the CSDDD and the German Supply Chain Act, where legislation is still open, and what work makes sense now.

The CSRD after the Omnibus: who still has to report

After Omnibus I, the CSRD only requires large companies with more than 1,000 employees and net turnover above EUR 450 million to publish sustainability reports. Amending Directive (EU) 2026/470 was adopted on 24 February 2026, published in the Official Journal on 26 February 2026 and entered into force 20 days later.

• Scope: more than 1,000 employees and net turnover above EUR 450 million.
• Timing: under the directive, financial years starting on or after 1 January 2027.
• First wave: for companies that have been in scope since financial year 2024 but no longer meet the new thresholds, the obligation ends for financial years starting on or after 1 January 2027. Member states may also exempt them for financial years starting in 2025 and 2026 (recitals 31 and 33 of Directive (EU) 2026/470). Whether and how a country uses this option is set by national law.
• Transposition deadline: 19 March 2027.

Status in Germany

Germany's CSRD implementation act has not been passed. The government bill of 3 September 2025 (Bundestag printed paper 21/1857) was aligned with the Omnibus through a coalition amendment of 31 March 2026, and the legal affairs committee held its hearing on 13 April 2026. The act is not in force: Section 289b of the German Commercial Code (HGB) still governs the non-financial statement under the 2017 CSR Directive Implementation Act (CSR-RUG) (status: October 2026). The financial year from which German companies report under the new rules will only be set by the act as passed.

Austria adopted the Omnibus thresholds in its Sustainability Reporting Act (NaBeG); parliament passed it on 21 January 2026 and it has been in force since late February 2026.

The CSDDD: due diligence duties from 2029

After the Omnibus, the EU Corporate Sustainability Due Diligence Directive (CSDDD) applies only to companies with more than 5,000 employees and turnover above EUR 1.5 billion. Member States must transpose it by 26 July 2028; it will apply from 26 July 2029.

For most companies, the CSDDD is therefore no longer a direct obligation. It still matters: large customers in scope may pass requirements on to their suppliers by contract. Suppliers to such groups should not dismantle their risk analysis and grievance processes.

German Supply Chain Act: what still applies

The LkSG (Lieferkettensorgfaltspflichtengesetz, the German Supply Chain Due Diligence Act) still applies: companies with 1,000 or more employees must continue to observe its human rights and environmental due diligence duties. Only reporting is suspended. Section 3(1) LkSG lists the duties:

• establish risk management and assign internal responsibility (section 4),
• carry out regular risk analyses (section 5),
• issue a policy statement and embed preventive measures (section 6),
• take remedial action (section 7),
• set up a grievance mechanism (section 8),
• address risks at indirect suppliers (section 9),
• document (section 10(1)) and report (section 10(2)).

Reporting suspended, amendment pending

The Federal Office for Economic Affairs and Export Control (BAFA) has not reviewed LkSG reports since autumn 2025. Reporting duties have been suspended since 7 November 2025, and the portal no longer accepts reports. The LkSG amendment act (printed paper 21/2474), however, has not been passed. It would abolish the reporting duty retroactively from 1 January 2023 and limit fines to serious breaches. After the first reading in the Bundestag on 16 January 2026, the procedure stalled. On 2 July 2026, the coalition announced that it would raise the scope to 5,000 employees and EUR 1.5 billion turnover from autumn 2026; whether and when a draft will follow is open. As of October 2026 the amendment is not in force: Section 10(2) LkSG still contains the reporting duty.

Switzerland: reporting and due diligence under the Code of Obligations

Since 2022, Swiss law has contained two sets of duties in the Code of Obligations that the EU Omnibus does not affect:

• Report on non-financial matters (Art. 964a et seq. OR): public interest entities which, together with the companies they control, have at least 500 full-time positions in two consecutive years and exceed total assets of CHF 20 million or turnover of CHF 40 million.
• Due diligence and reporting on conflict minerals and child labour (Art. 964j et seq. OR and the related ordinance VSoTr): for the companies covered there.

New legislation in preparation

On 1 April 2026, the Federal Council opened a consultation on a Federal Act on Sustainable Corporate Governance (NUFG), which ran until 9 July 2026. The draft is an indirect counter-proposal to the popular initiative "For responsible large companies" and is modelled on the EU Omnibus. It provides for due diligence duties for around 30 large companies, reporting duties for around 100 instead of today's roughly 200 companies, external assurance, supervision by the Federal Audit Oversight Authority (RAB) and two liability options. SMEs would not be directly affected. When it opened the consultation, the Federal Council gave no date for its dispatch to parliament; as of October 2026 the act is a draft.

Swiss groups with EU subsidiaries should also check whether individual EU entities fall under the CSRD in their own right. For third-country undertakings, the Omnibus raises the threshold for net turnover in the EU to EUR 450 million; for the EU subsidiary or branch, a net turnover threshold of EUR 200 million applies (recital 26 of Directive (EU) 2026/470). The group should clarify with its auditor from which financial year these third-country rules apply.

The rules at a glance: who, from when, current status

What companies should do now

Companies should reassess which rules apply to them and adjust ongoing projects, without dismantling processes they still need for the LkSG, the Swiss Code of Obligations or customer requirements. A workable sequence:

1. Check applicability per entity and per rule: employees, turnover, total assets, group structure, reference dates.
2. Adjust ongoing CSRD projects to the new scope and replan the effort.
3. Continue LkSG due diligence: risk analysis, prevention, remediation, grievance mechanism and documentation.
4. Review the supplier code of conduct and contracts so that they match the actual obligations.
5. In Switzerland, continue the reports under Art. 964a and 964j OR and monitor the NUFG draft.
6. Track legislation and add deadlines to a regulatory calendar.
7. Assign responsibilities across compliance, legal, procurement, sustainability and finance, and document results for the statutory auditor.

Which roles the work requires

The work usually falls to three profiles that are rarely all available in-house:

• Supply chain and human rights compliance officer: risk analysis, supplier assessment, grievance mechanism, remediation.
• Legal counsel: scope and group questions, supplier contracts, liability, legislative monitoring.
• Project lead: coordination between sustainability, finance, procurement and the auditor.

Alpinum Solutions provides such professionals to companies in Switzerland and Germany through staff leasing (Personalverleih in Switzerland, Arbeitnehmerüberlassung in Germany) or freelancing, part time or full time. The client steers the assignment: in staff leasing it gives the professional instructions; in freelancing the professional works independently within the agreed mandate. How supply chain duties fit into a compliance management system is covered in a separate guide.

Limits and risks

• Legislation in flux: CSRD transposition and the LkSG amendment in Germany and the NUFG in Switzerland are not complete. Decisions should rest on the law as it stands at the time.
• No legal advice: Alpinum is not a law firm. Whether a company must report is for the company to assess, where necessary with its auditor or external counsel.
• Contractual duties remain: companies outside the statutory scope can still be bound to provide sustainability information through customer contracts or financing terms.
• Keep the knowledge: if projects are paused, keep data, risk analyses and supplier assessments; they will be needed again if obligations return or customers ask.

Frequently asked questions about CSRD, CSDDD and supply chain laws after the Omnibus

Do I still have to report after the Omnibus?

Under the CSRD, only companies with more than 1,000 employees and net turnover above EUR 450 million will have to report. What counts, however, is national transposition, which Germany has not yet completed; until then the CSR-RUG of 2017 applies. In Switzerland, Art. 964a OR determines whether a report on non-financial matters is required.

What applies in Switzerland?

Since 2022, Switzerland has required a report on non-financial matters (Art. 964a et seq. OR) and due diligence and reporting on conflict minerals and child labour (Art. 964j et seq. OR, VSoTr). The EU Omnibus does not change this. The planned NUFG would reorganise the rules; its consultation ran until 9 July 2026.

Do I still have to file an LkSG report with BAFA?

Not at present. LkSG reporting duties have been suspended since 7 November 2025, and the BAFA portal does not accept reports. The due diligence duties under section 3 LkSG, including internal documentation, still apply to companies with 1,000 or more employees. The statutory abolition of the reporting duty has not yet been passed.

When does the CSDDD apply?

After Omnibus I, Member States must transpose the CSDDD by 26 July 2028, and it will apply from 26 July 2029. Only companies with more than 5,000 employees and turnover above EUR 1.5 billion are covered. Smaller companies will mostly feel it indirectly, through requirements passed on by large customers.

Does the Omnibus affect Swiss companies?

The Omnibus applies directly only in the EU. Swiss groups are affected where their EU subsidiaries meet the thresholds or EU customers pass on requirements. For obligations in Switzerland, Art. 964a and 964j et seq. OR remain decisive; the NUFG draft is modelled on the Omnibus.

Next step

If applicability assessments, LkSG due diligence or Swiss reporting need extra capacity, Alpinum provides compliance and legal professionals. Selected profiles are usually available within 48 hours; the start date of the assignment is agreed between the client and Alpinum.

• Regulatory compliance and regulatory change
• Regulatory calendar for legal and compliance
• Interim compliance
• Discuss your requirements

Last updated: 30 October 2026.