France: Updating of CSRD and CS3D Directives
The ”Omnibus” Directive relating to corporate extra-financial reporting and due diligence took effect on 19 March 2026.
After much debate, the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D) have been updated. The most important change relates to the increase in application thresholds.
Regarding the CSRD, only companies with over 1,000 employees and €450 million net turnover will need to publish a sustainability report. For non-EU companies with subsidiaries or branches in the EU, the threshold applicable to such subsidiary or branch will now be €200 million and the non-EU company should also have an overall turnover in the EU of €450 million.
Companies will be required to publish their first sustainability report in 2028 based on 2027 data.
In connection, for the CS3D, only companies with more than 5,000 employees and a net worldwide turnover of more than € 1.5 billion will be within scope and obliged to implement their due diligence requirements effective from 2029.
Key Action Points for Human Resources and In-House Counsel
Check if your company will need to publish a CSRD report in 2028 and set data collection rules by 31 December 2026 at the latest.
