EU Procurement Supply Chain Due Diligence 2026: CSDDD, Forced Labour Regulation, and Tender Compliance

CSDDD Application Timeline and Scope

The CSDDD thresholds in the article table reflect the final adopted text (Directive 2024/1760). A key practical clarification: companies with more than 1,000 employees and more than €450M global turnover must comply from July 2027; those above 500 employees and €150M from July 2028. These thresholds are lower than earlier draft versions, meaning a wider range of EU suppliers face mandatory obligations sooner than many anticipated. The cascade effect on procurement is already visible — contracting authorities, particularly in France and the Netherlands, are including CSDDD readiness declarations in pre-qualification questionnaires for above-threshold services contracts from 2025 onwards, treating CSDDD preparedness as a proxy for supply chain management maturity even before obligations formally apply.

What CSDDD-Compliant Suppliers Must Demonstrate

CSDDD creates six core obligations that directly affect how large suppliers approach public tenders:

• Due diligence policy: A written company policy on human rights and environmental due diligence, updated annually, with board-level approval and supply chain risk mapping methodology.
• Supply chain mapping: Identification of direct suppliers (Tier 1) and, where risk indicators are present, indirect suppliers (Tier 2+). High-risk sectors — textiles, electronics, minerals, food — require deeper chain visibility.
• Remediation and grievance mechanisms: A notification system allowing workers, communities, and civil society to report adverse impacts in the company's supply chain — including a commitment to remediate confirmed violations.
• Climate transition plan: CSDDD requires large companies to adopt a climate transition plan aligned with the Paris Agreement 1.5Β°C pathway — with science-based targets and progress reporting.

The Forced Labour Regulation: Market Bans Affecting Public Contracts

Regulation 2024/3015 gives EU authorities (the European Commission and member state competent authorities) the power to investigate and ultimately ban products from the EU market if they are found to be made using forced labour — at any point in the supply chain, anywhere in the world.

The procurement implications are significant:

• Banned products cannot be procured: If a product category receives a market withdrawal decision under the Regulation, contracting authorities cannot award public contracts for those products. This creates a compliance obligation for buyers as well as suppliers.
• Country-of-origin documentation: Tender specifications for goods in high-risk categories (solar panels, batteries, polysilicon, cotton textiles, electronics) are increasingly requiring suppliers to provide country-of-origin certificates and supply chain traceability documentation — anticipating future forced labour investigations.
• Risk-based prioritisation: The Commission will prioritise investigations using a geographic and sector risk methodology. Xinjiang-origin goods, cobalt from DRC, and certain Southeast Asian textile production are identified as high-risk in the Regulation's implementing guidance.