EU CSDDD: Removal of the Climate Transition Plan Obligation and Its Separation from CSRD Disclosure
ENFORCEMENT TIMELINE
The obligation in force from 25 July 2024 was fully removed by the Omnibus reform on 18 March 2026 (a separate CSRD disclosure obligation remains)
Overview
This card explains how the climate transition plan obligation under the EU Corporate Sustainability Due Diligence Directive (CSDDD) changed as a result of the 2026 Omnibus reform.
Article 22 of the original CSDDD (Directive (EU) 2024/1760) required in-scope companies to adopt and implement a transition plan aligned with the Paris Agreement's 1.5°C goal and the EU's 2050 climate neutrality target, including five-year interim Scope 1, 2, and 3 emissions-reduction targets and board-level oversight.
The Omnibus I reform (Directive (EU) 2026/470), in force since 18 March 2026, deleted this obligation from the CSDDD entirely. In-scope companies are no longer legally required to adopt or implement a transition plan under the CSDDD.
This does not mean all climate-related disclosure obligations have disappeared, however. Under the CSRD (Corporate Sustainability Reporting Directive), companies that already have a transition plan must still disclose it under the ESRS E1 standard. What the CSDDD required was substantive adoption and implementation; what the CSRD requires is disclosure of a plan if one exists. The two are legally distinct.
Enforcement Timeline
25 July 2024: CSDDD enters into force, including Article 22 (obligation to adopt and implement a climate transition plan).
26 February 2025: European Commission's Omnibus proposal includes removal of the transition plan obligation.
16 December 2025: European Parliament adopts the reform, including the removal.
18 March 2026: Omnibus I enters into force; Article 22's obligation to adopt and implement a transition plan is deleted from the CSDDD. The separate CSRD disclosure obligation (where a plan exists) remains unaffected.
26 July 2029: CSDDD's own application date (though the transition plan obligation itself no longer applies from this or any date).
Business Impact
The financial and operational impact originally expected from a mandatory transition plan under the CSDDD no longer applies, since the Omnibus reform removed the obligation entirely. Two points are worth noting, however.
First, companies in scope of the CSRD — a broader population than those in scope of the CSDDD — must still disclose their transition plan under ESRS E1 if they have one. Adoption itself is not mandated, but investor and customer expectations mean many large companies are expected to continue developing transition plans regardless.
Second, the nature of the pressure reaching Japanese and other suppliers has shifted: rather than a legally mandated request stemming from a CSDDD obligation, it now comes from EU companies' voluntary climate strategy and investor relations activities. The request itself has not disappeared — its legal basis has changed.