> Title: EU Due Diligence Directive: What Changed for Suppliers > Source: https://surajmal.com/blog/2026/11/eu-due-diligence-directive-suppliers > Publisher: Surajmal Shobhachand [SSL Newsroom](/blog) Compliance # The EU Due Diligence Directive After the 2026 Amendment Kolkata 02 NOVEMBER 2026 By Surajmal Editorial Team9 min read Published 2 November 2026 Supplier questionnaires started citing the EU Corporate Sustainability Due Diligence Directive well before it applied to anyone. In February 2026 the directive was amended, and the amendment changed both who is covered and when. For an apparel supplier, the practical effect is smaller than the headlines suggest and worth understanding precisely, because the questionnaires will keep coming either way. ## What is the EU due diligence directive, and who does it bind? Directive (EU) 2024/1760 sets out corporate sustainability due diligence obligations: a duty on companies in scope to identify, prevent, mitigate and account for adverse human-rights and environmental impacts connected with their own operations, those of their subsidiaries and those of business partners in their chains of activities. [\[1\]](https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng "Source 1: eur-lex.europa.eu: Directive 2024/1760") [\[2\]](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32026L0470 "Source 2: eur-lex.europa.eu: CELEX:32026L0470") The obligation-holder is the company in scope. A supplier outside the EU is not a regulated person under the directive and has no direct duty under it. It is reached, as under national due diligence laws, through the contract with a company that does have a duty. That structural point is the one worth holding on to when a questionnaire arrives with the directive named in its covering note. The question is never "what does the directive require of us"; it is "what has our customer contracted for, and what evidence closes it". ## What changed in February 2026? Directive (EU) 2026/470 of 24 February 2026 amends Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760, as regards certain corporate sustainability reporting requirements and certain corporate sustainability due diligence requirements. [\[2\]](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32026L0470 "Source 2: eur-lex.europa.eu: CELEX:32026L0470") Three changes matter to a supply base. The size thresholds went up substantially, and the test is not the same on both sides of the EU border. An EU company is in scope where it had more than 5,000 employees on average and a net worldwide turnover of more than 1,500 million euro, both together, up from 1,000 and 450 million. A company incorporated outside the EU is in scope where it generated a net turnover of more than 1,500 million euro in the Union, with no employee threshold at all. For franchising and licensing arrangements the royalty threshold moves to 75 million euro and the turnover threshold to 275 million euro. That asymmetry is the part worth reading twice. A large non-EU group selling into Europe can be in scope on turnover alone, however few people it employs. The application date moved. Member states transpose the directive into national law by 26 July 2028, and companies in scope apply it from 26 July 2029. The reporting measures under Article 16 run to a separate clock, for financial years starting on or after 1 January 2030. The amending directive's recitals give preparation time against the Commission's guidelines as the reason for the postponement. And the expectations around gathering information from business partners were tightened, in the supplier's favour. See the section on information requests below. Before the 2026 amendment After Employee threshold, EU company more than 1,000 more than 5,000 Net worldwide turnover, EU company more than 450 million euro more than 1,500 million euro Non-EU company Net turnover in the EU, staged more than 1,500 million euro net turnover in the EU, no employee threshold Franchising royalties Lower threshold 75 million euro Franchising turnover Lower threshold 275 million euro Transposition by member states 26 July 2027 under the original text 26 July 2028 Application Staged, from 2027 onward under the original text 26 July 2029 for all companies in scope ## Which companies are now in scope Far fewer than were in scope under the original text, and this is the change most likely to affect a supplier's day-to-day. A threshold of more than 5,000 employees and more than 1,500 million euro of net worldwide turnover captures the largest EU retail groups and very little else. A mid-sized European brand that was preparing for the directive under the original thresholds is, on these numbers, outside it. A non-EU group is measured differently, on 1,500 million euro of turnover generated in the Union, so a large overseas retailer selling into Europe can be in scope where a similarly sized EU brand is not. That does not mean the questionnaires stop. Two reasons. First, national due diligence law continues to apply on its own terms; the German Supply Chain Act, for instance, has a much lower employee threshold and its own duties, which we cover in [what the German Supply Chain Act asks of an apparel supplier](/blog/2026/02/german-supply-chain-act-apparel-suppliers). Second, a company outside the directive can still be a supplier to one inside it, and requirements pass down a chain by contract regardless of who is directly regulated. The practical reading for a supplier is therefore: the directive narrowed, the contractual environment did not. ## When does it start to apply? 26 July 2029, for all companies in scope, with member states transposing it by 26 July 2028. The original text staged application across waves; the amendment collapses that into a single date, with the recitals citing preparation time against the Commission's guidelines as the reason. [\[2\]](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32026L0470 "Source 2: eur-lex.europa.eu: CELEX:32026L0470") Three years is long enough for the requirement to feel distant and short enough for the preparation to be real. The buying side is already writing contract language against it, because supply agreements signed now will still be running in 2029, and a clause is cheaper to insert at signature than to negotiate mid-term. For a supplier this means the directive shows up first as drafting, not as an audit. A due-diligence annex referencing an instrument that does not yet apply is a normal thing to be asked to sign, and reading it on its own terms is worth the half hour. ## How does a directive that binds buyers reach a supplier? Through the same three mechanisms every due-diligence regime uses. Mechanism What it looks like in a supply agreement What the supplier actually provides Selection Pre-nomination assessment, questionnaire, site visit Completed assessment with current attachments Contractual assurance A due-diligence annex or code of conduct to countersign The signed document, and the pass-down to its own suppliers Verification Audit rights, agreed protocol, corrective action process Audit report, corrective action plan, closure evidence Nothing on the right-hand column is new. It is the same file a German buyer asks for under national law, the same file a retailer asks for under its own programme, and the same file an amfori or Sedex member asks for under a scheme. The instrument named on the covering note changes; the evidence does not. That is the single most useful thing to know about the regulatory churn of the last three years. Thresholds move, dates move, national laws are amended, and the underlying supplier-side artefacts have stayed constant: a current social audit with its follow-up, a management-system certification, materials certification and testing tied to the actual order, and a countersigned commitment. ## What the amendment changes about information requests This is the part of the amendment aimed squarely at the burden that lands on suppliers. [\[2\]](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32026L0470 "Source 2: eur-lex.europa.eu: CELEX:32026L0470") The amending directive's recitals set out that companies should only request information from business partners where that information is necessary, and that where the business partner has fewer than 5,000 employees, information should be requested only where it cannot reasonably be obtained by other means. They also record that companies should be able to prioritise assessing adverse impacts involving direct business partners. Read together, those are a corrective to the questionnaire cascade: the pattern in which a requirement aimed at a handful of very large companies is passed down verbatim, tier by tier, until a trims vendor with forty employees is asked to complete a document written for a listed retailer. A supplier can use this constructively without being obstructive. Where a request duplicates information the buyer already holds, say so and point to where it sits. Where a request reaches past the direct relationship into a tier the supplier cannot verify, offer what can be evidenced and be specific about what cannot. Both responses are more useful to a compliance function than a completed form with confident answers behind it. ## How does this sit alongside national due diligence laws? They are separate instruments with separate thresholds, and a buyer can be subject to one and not the other. German Supply Chain Act EU due diligence directive as amended Who is bound Companies with a seat or branch in Germany above the employee threshold Companies in scope EU-wide above the amended thresholds Employee threshold 1,000 in Germany, since 1 January 2024 5,000 Reach into the chain Direct suppliers routinely; indirect suppliers on substantiated knowledge Business partners in the chain of activities, with direct partners able to be prioritised Applies from In force 26 July 2029 What reaches a supplier Contractual assurance, training, risk-based contractual checks Selection, contractual assurance, verification The overlap is the reason a single well-kept evidence file serves both. The differences are why a supplier should read the clause in front of it rather than assume which instrument it derives from. ## How should a supplier read a due-diligence annex? Clause by clause, against what can actually be evidenced. Four questions cover most of it. What exactly is being warranted, and about whom. A commitment to meet a defined standard at the supplier's own operations is a different undertaking from a warranty about conditions at every party upstream. The first is verifiable and the second is not, and signing the second creates an exposure that no audit programme can close. How far the audit right reaches, and on what notice. A defined protocol, an auditor who is named or approvable, an agreed frequency and a clear position on who pays are all normal to ask for. An unlimited right of access with no scope attached is not a compliance mechanism so much as an open question. What happens on a finding. The workable version is a corrective action plan with a timetable, escalation if the plan is not met, and termination as a last resort. A clause that allows termination on any finding at all makes reporting an issue more dangerous than concealing one, which is the opposite of what the whole regime is trying to achieve. Which version of the standard applies. Codes of conduct are revised, and an annex that binds the supplier to the buyer's code "as amended from time to time" is a commitment to something not yet written. Where that language stays, ask for notice and a reasonable period to implement. None of these are adversarial points. They are the same questions the buyer's own legal function asked before the annex was drafted, and a supplier that raises them is easier to work with over a five-year programme than one that signs everything and renegotiates under pressure later. ## What a supplier should have ready anyway Regulatory timing is not something a supply base can control. What it can control is whether the file is current when the request lands. - A social audit against a recognised protocol, with the corrective action plan and dated closure evidence filed alongside it. - Quality management certification, with the scope checked against the processes actually used on the programme. - Materials certification covering the fibres and chemistry the programme uses, with transaction documents where the scheme requires them. - Restricted-substance and physical testing tied to the specific order, not to a generic annual sample. - The countersigned code of conduct or due-diligence annex, in its current version, with the superseded versions kept. - A materials register that ties a purchase order to a mill and a dye lot, so a traceability question has an answer within days. The [certification groups](/sustainability) page sets out which standards and which independent bodies sit behind the programmes we run, and the [European Union import guide](/markets/european-union) covers the destination-side requirements that travel with the order. ## FAQ **Does the EU due diligence directive apply to suppliers outside the EU?** No. It places obligations on companies in scope. Suppliers are reached through contractual assurances in the supply agreement, not by direct application of the directive. **What are the size thresholds after the 2026 amendment?** 5,000 employees and 1,500 million euro of net turnover, raised from 1,000 employees and 450 million euro. Franchising and licensing thresholds moved to 75 million euro of royalties and 275 million euro of turnover. **When does the directive apply?** 26 July 2029 for all companies in scope, following the postponement in the February 2026 amending directive. **Does the amendment mean suppliers will be asked for less?** Possibly less duplication. The amending directive's recitals say information should be requested from business partners only where necessary, and from partners with fewer than 5,000 employees only where it cannot reasonably be obtained by other means. **Should a supplier sign a due-diligence annex referencing a directive that is not yet in force?** That is a commercial decision, and it is a normal request. Read the annex on its own terms: what is warranted, how far up the chain it reaches, what audit rights it grants, and what happens on a finding. Those terms bind on signature whatever the directive's timetable does. Related pages - [European Union import guide](/markets/european-union) - [Certifications](/sustainability) Share[](https://www.linkedin.com/sharing/share-offsite/?url=https%3A%2F%2Fsurajmal.com%2Fblog%2F2026%2F11%2Feu-due-diligence-directive-suppliers) [](https://twitter.com/intent/tweet?url=https%3A%2F%2Fsurajmal.com%2Fblog%2F2026%2F11%2Feu-due-diligence-directive-suppliers&text=The%20EU%20Due%20Diligence%20Directive%20After%20the%202026%20Amendment) [](https://wa.me/?text=The%20EU%20Due%20Diligence%20Directive%20After%20the%202026%20Amendment%20https%3A%2F%2Fsurajmal.com%2Fblog%2F2026%2F11%2Feu-due-diligence-directive-suppliers) [](mailto:?subject=The%20EU%20Due%20Diligence%20Directive%20After%20the%202026%20Amendment&body=https%3A%2F%2Fsurajmal.com%2Fblog%2F2026%2F11%2Feu-due-diligence-directive-suppliers) Surajmal Editorial Team The Surajmal Editorial Team writes from inside a working textile export house in Kolkata, drawing on experience manufacturing garments, fabrics, and yarns for global retail buyers since 1968. Every article is reviewed by practitioners who source, sample, and ship the products they write about. On this page - [What is the EU due diligence directive, and who does it bind?](#what-is-the-eu-due-diligence-directive-and-who-does-it-bind) - [What changed in February 2026?](#what-changed-in-february-2026) - [Which companies are now in scope](#which-companies-are-now-in-scope) - [When does it start to apply?](#when-does-it-start-to-apply) - [How does a directive that binds buyers reach a supplier?](#how-does-a-directive-that-binds-buyers-reach-a-supplier) - [What the amendment changes about information requests](#what-the-amendment-changes-about-information-requests) - [How does this sit alongside national due diligence laws?](#how-does-this-sit-alongside-national-due-diligence-laws) - [How should a supplier read a due-diligence annex?](#how-should-a-supplier-read-a-due-diligence-annex) - [What a supplier should have ready anyway](#what-a-supplier-should-have-ready-anyway) - [FAQ](#faq) More from the newsroom - [Compliance · 9 min Sweden Apparel Labelling: EU Textile-Labelling Rules](/blog/2026/09/sweden-apparel-labelling-requirements) - [Compliance · 10 min Spain Apparel Labelling: Spanish-Language Rules and the Manufacturer ID Field](/blog/2026/09/spain-apparel-labelling-requirements) - [Compliance · 9 min Netherlands Apparel Labelling: The Warenwet Route to the EU Fibre Rule](/blog/2026/09/netherlands-apparel-labelling-requirements) START A CONVERSATION ## Ready to source with _confidence?_ Send a brief and we'll reply within 24 hours, with a first sample in 4 to 10 days. 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