Directive (EU) 2024/1760, amended by (EU) 2026/470
The EU due diligence directive hits fewer companies. Your customers are still among them.
After the Omnibus package only companies above 5,000 employees and EUR 1.5 billion turnover fall in scope directly, uniformly from 26 July 2029. Those companies are the key customers for many Swiss SMEs.
The Corporate Sustainability Due Diligence Directive was designed as a broad European duty of care. Amending Directive (EU) 2026/470, published in February 2026 and in force since 18 March 2026, narrowed the scope sharply, removed the staggered application waves and dropped the harmonised liability regime.
For a Swiss SME the position is clear: you are not obligated. Your large customer is. And they can only discharge their duty by collecting information from their chain. The directive limits what may be demanded from smaller suppliers, but it does not remove the demand.
Who is affected
- EU companies above 5,000 employees and above EUR 1.5bn net turnover.
- Third-country companies – Swiss ones included – with comparable turnover in the EU market.
- Every other supplier: indirectly, through contracts and requests from obligated buyers.
What applies after Omnibus I
- Application
- One single date, 26 July 2029; transposition into national law by 26 July 2028.
- Threshold
- Above 5,000 employees and above EUR 1.5bn turnover – the staggered waves are gone.
- Risk approach
- A risk-based approach instead of full mapping of the entire chain.
- Liability
- No harmonised EU liability regime; national law applies.
- Chain protection
- Limits on what information may be demanded from smaller suppliers.
How SCRM covers it
Ability to answer
Master data, sites, certificates and codes maintained once – every customer request answered from the same record.
Manage customer demands
Who wants what by when? Requirements as tasks with deadlines instead of an email thread.
Map your own chain
Your upstream suppliers too, with country, commodity group and risk class.
Evidence with expiry
What expires gets renewed before the customer asks.
Frequently asked
Are we in scope as a Swiss SME?
Directly only if you meet the thresholds in the EU market, which very few Swiss companies do. Indirectly, through customers, many are.
Scope is shrinking. Can we postpone?
For your own obligation, yes. For sales, hardly: large customers ask for evidence regardless of whether the duty bites in 2029, because they are building their processes now.
What about protection for small suppliers?
Obligated companies may not demand unlimited information from smaller suppliers. In practice, holding the standard data in structured form keeps you comfortably on the safe side.
As of July 2026, following Directive (EU) 2026/470. Not legal advice.