CSDDD Datahub reveals law covers fewer than 3,400 EU-based corporate groups

Like the European Commission(opens in new window) , SOMO has identified approximately 7,000 companies that currently meet the threshold criteria of the EU Corporate Sustainability Due Diligence Directive (CSDDD). However, many of these companies are part of a corporate group containing several subsidiaries or holding companies that operate under the same umbrella. Data analysis by SOMO – based on companies’ most recent reported revenues and employee figures – shows that in practice, the CSDDD will cover only 4,280 corporate groups, of which just under 3,400 are based in the EU. For example, within these 7,000 companies, there are several corporate groups, of which over ten subsidiary companies meet the threshold criteria individually (e.g. several car manufacturers and supermarkets).  

True scope: number of corporate groups vs. number of companies

This means that the actual number of corporations that will have to implement the CSDDD is substantially lower than the European Commission(opens in new window) ’s simple count of companies would suggest. While standardised statistics on the number of corporate groups in the EU do not appear to be available, previous SOMO research showed that the CSDDD would only cover less than 0.1 per cent(opens in new window) of all companies in the EU.

SOMO’s analysis shows that the actual coverage of the CSDDD is, in practice, even smaller. It also shows that claims about the CSDDD having an enormous impact on the EU economy simply do not match the reality of the extremely small number of companies that will be within the scope of the law. In February 2025, the European Commission is set to publish an omnibus legislative proposal to amend three key pillars of the European Green Deal: the CSDDD, the Corporate Sustainability Reporting Directive (CSRD), and the Taxonomy Regulation. It is crucial that the Commission refrain from reinforcing false narratives about the supposed burdensome impact of the CSDDD on the EU economy as a disguise for deregulatory policies that boost corporate profits at the expense of people and the planet(opens in new window) .

Ample preparation time for companies

The CSDDD will enter into force in three phases. 31 per cent of the corporate groups SOMO has identified will have to comply with the CSDDD in 2027, followed by 18 per cent in 2028. Over 50 per cent of the corporate groups will only meet the threshold criteria in 2029, leaving them with no less than 4.5 years to prepare for compliance with the law.

CSDDD coverage: key sectors

The companies covered by the CSDDD mainly operate in the manufacturing (24.6%), services (19.1%), and wholesale and retail (16.2%) sectors. Notably, one out of every five companies that will have to comply with the CSDDD is a provider of financial services, though the holding companies of many corporate groups are included in this category. The CSDDD largely exempts financial institutions such as banks and insurers from the obligation to conduct due diligence on adverse impacts associated with their investments and financial services, which makes the total number of corporate groups directly affected by the CSDDD’s obligations even smaller in practice.

Breaking down barriers: access to information and corporate accountability

In countries that already have corporate accountability legislation in place, not knowing which companies fall within the scope of the law has been a crippling obstacle(opens in new window) for civil society and workers to effectively hold companies to account for their impacts on human rights, the environment, and the climate. The purpose of SOMO’s CSDDD Datahub is to break down this barrier and make it possible to identify whether companies, suppliers, or buyers can be held accountable under the CSDDD.     

About SOMO’s CSDDD Datahub

SOMO has compiled the Datahub based on data from Moody’s Orbis, supplemented with data from the LSEG Workspace and Company.info databases, national business registries, and the annual accounts and websites of companies. The Orbis database was also used by the European Commission(opens in new window) and Wageningen University & Research(opens in new window) to map companies covered by the CSDDD. While SOMO has aimed to ensure the Datahub is as complete and accurate as possible, these data sources have their limitations. In particular with regard to non-EU companies, the list is incomplete. SOMO is planning to update the CSDDD Datahub on a regular basis.

SOMO also provides pro bono research to activists, communities, trade unions, journalists, and others on corporate structures and supply chains through The Counter.