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supply chain info corner

The Corporate Sustainability Due Diligence Directive (CSDDD) marks a significant shift in regulatory and compliance expectations for companies operating within the European Union and beyond. As the directive must be transposed into the national laws of Member States, it is essential for businesses to remain informed and ensure compliance with these evolving requirements. Recent discussions at the EU level regarding the Omnibus proposals have, unfortunately, added to the uncertainty faced by companies.

Our CSDDD Transposition Tracker is designed to provide you with up-to-date information on the implementation status of the CSDDD across the jurisdictions where Schoenherr operates, ensuring you have the necessary guidance to navigate these changes effectively.

The Tracker highlights the current supply chain compliance regimes, the stages of CSDDD implementation, the names of the relevant legislation, the authorities responsible for monitoring compliance, and any instances of gold-plating. While the CSDDD only needs to be transposed into the national laws of Member States, we also include our non-EU jurisdictions, indicating whether similar regimes are in place. This comprehensive overview will help you understand the regulatory landscape and prepare for the implications of the CSDDD in your operations.

We are committed to keeping the Tracker as current as possible, with regular updates based on the latest information. Should there be any amendments or new developments, we will promptly reflect these changes to ensure you have the most accurate and relevant information at your fingertips.

Click through our map to learn more about the status of CSDDD implementation in each country.

Information as of: 15 July 2025.

 

Select a country to find out more about the supply chain compliance regime in that country:

AlbaniaAustria | Bosnia & Herzegovina | Bulgaria | Croatia | Czech Republic | Hungary | Moldova | MontenegroNorth Macedonia | Poland Romania | Serbia | Slovakia | Slovenia 

 

Albania

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

Albania is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

N/A

 

Gold plating?

N/A

 

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Austria

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

There is no published draft legislation yet. The Stop-the-Clock Directive extends the deadline for Member States to implement the CSDDD by one year, from 26 July 2026 to 26 July 2027.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

Not yet known

 

Gold plating?

Not yet known

 

back up

 


 

Bosnia and Herzegovina

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

Bosnia & Herzigovina is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

N/A

 

Gold plating?

N/A

 

back up

 


 

Bulgaria

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

There is no publicly available draft legislation yet, nor any information on initial discussions within intergovernmental working groups. The Stop-the-Clock Directive extends the deadline for Member States to implement the CSDDD by one year, from 26 July 2026 to 26 July 2027.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

Not yet known

 

Gold plating?

Not yet known

 

back up

 


 

Croatia

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

There is no publicly available draft legislation yet, nor any information on initial discussions within intergovernmental working groups. The Stop-the-Clock Directive extends the deadline for Member States to implement the CSDDD by one year, from 26 July 2026 to 26 July 2027.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

Not yet known

 

Gold plating?

Not yet known

 

back up

 


 

Czech Republic

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

There is no published draft legislation yet. The Stop-the-Clock Directive extends the deadline for Member States to implement the CSDDD by one year, from 26 July 2026 to 26 July 2027.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

Not yet known

 

Gold plating?

Not yet known

 

back up

 


 

Hungary

Is a supply chain compliance regime currently in place?

Yes

 

What is the current stage of CSDDD implementation into national law?

"Act CVIII of 2023 (the 'ESG Act') was adopted at the end of 2023 and entered into force on 1 January 2024. While the ESG Act does not explicitly reference the implementation of the CSDDD, it incorporates certain elements of it—most notably, supply chain due diligence obligations for businesses within its scope. The first ESG reports under the ESG Act are due in 2025.

A recent amendment to the ESG Act, effective since 20 June 2025, significantly narrows the range of entities subject to ESG reporting obligations and introduces additional relief for the initial reporting years regarding certification, submission, and publication requirements. SMEs benefit from further specific exemptions and transitional measures designed to reduce their administrative burden."

 

What is the name of the implementing legislation?

No formal implementation yet. However, the ESG Act has pre-emptively incorporated certain elements of the CSDDD. Please refer to the question before this one for more details.

 

Which authority is responsible for monitoring compliance?

No formally designated authority yet. The Supervisory Authority for Regulated Activities (in Hungarian: Szabályozott Tevékenységek Felügyeleti Hatósága) monitors compliance with the ESG Act. Please refer to the second question for more details.

 

Gold plating?

N/A

 

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Moldova

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

Moldova is not an EU Member State; therefore, no implementation is required. There are no plans to pass similar legislation.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

N/A

 

Gold plating?

N/A

 

back up

 


 

Montenegro

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

Montenegro is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

N/A

 

Gold plating?

N/A

 

back up

 


 

North Macedonia

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

North Macedonia is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

N/A

 

Gold plating?

N/A

 

back up

 


 

Poland

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

There is no publicly available draft legislation yet, nor any information on initial discussions within intergovernmental working groups. The Stop-the-Clock Directive extends the deadline for Member States to implement the CSDDD by one year, from 26 July 2026 to 26 July 2027.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

Not yet known

 

Gold plating?

Not yet known

 

back up

 


 

Romania

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

There is no publicly available draft legislation yet, nor any information on initial discussions within intergovernmental working groups. The Stop-the-Clock Directive extends the deadline for Member States to implement the CSDDD by one year, from 26 July 2026 to 26 July 2027.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

Not yet known

 

Gold plating?

Not yet known

 

back up

 


 

Serbia

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

Serbia is not an EU Member State; therefore, no implementation is required. However, as a candidate for accession, it has committed to aligning its legislation with the EU acquis. There are no plans to pass similar legislation.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

N/A

 

Gold plating?

N/A

 

back up

 


 

Slovakia

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

There is no publicly available draft legislation yet, nor any information on initial discussions within intergovernmental working groups. The Stop-the-Clock Directive extends the deadline for Member States to implement the CSDDD by one year, from 26 July 2026 to 26 July 2027.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

Not yet known

 

Gold plating?

Not yet known

 

back up

 


 

Slovenia

Is a supply chain compliance regime currently in place?

No

 

What is the current stage of CSDDD implementation into national law?

There is no publicly available draft legislation yet, nor any information on initial discussions within intergovernmental working groups. The Stop-the-Clock Directive extends the deadline for Member States to implement the CSDDD by one year, from 26 July 2026 to 26 July 2027.

 

What is the name of the implementing legislation?

N/A

 

Which authority is responsible for monitoring compliance?

Not yet known

 

Gold plating?

Not yet known

 

back up

If you do have any questions about The Corporate Sustainability Due Diligence Directive ("CSDDD"), please do not hesitate to contact us. 

Austria

Johannes
Frank

Partner

austria vienna

Carina
Fürnkranz

Associate

austria vienna

Stefan
Holub

Attorney at Law

austria vienna

Balkan

Petar
Vučinić

Attorney at Law

montenegro

Bulgaria

Croatia

Ana
Mihaljević*

Attorney at Law in cooperation with Schoenherr

croatia

Czech Republic

Jan
Kupčík

Attorney at Law

czech republic

Hungary

Gergely
Horváth

Attorney at Law

hungary

Márk
Kovács

Attorney at Law

hungary

Poland

Katarzyna
Sulimierska

Partner

poland

Romania

Georgiana
Bădescu

Partner

romania

Cristiana
Manea

Managing Attorney at Law

romania

Sabina
Aionesei

Attorney at Law

romania

Slovakia

Michal
Lučivjanský

Partner

slovakia

Slovenia

Matej
Črnilec

Partner in cooperation with Schoenherr

slovenia