How the EU’s Omnibus I package changed the rules of supply chain due diligence, and where JAGGAER fits in.
If you’ve been tracking the Corporate Sustainability Due Diligence Directive (CSDDD) since it passed in 2024, you’ve probably noticed the goalposts moved. In February 2025, the European Commission proposed an “Omnibus” package to simplify sustainability reporting across the board. After a year of negotiation, the final text entered into force in March 2026, and it meaningfully scaled back what CSDDD requires, and to whom it applies.
For procurement leaders who spent the last two years preparing for CSDDD, the natural question is: does this mean I can stand down? For most, not quite, but the shape of the work has changed, and it’s worth understanding how.
What actually changed
The Omnibus package didn’t kill CSDDD. It narrowed it:
- Fewer companies are in scope. The threshold jumped to companies with more than €1.5 billion in net turnover and 5,000+ employees (EU companies), or more than €1.5 billion in EU turnover (non-EU companies). That’s a much smaller pool than the directive originally targeted.
- Lighter penalties. Fines are now capped at 3% of a company’s net worldwide turnover, replacing the open-ended national penalty regimes originally proposed.
- The climate transition plan requirement is gone. Companies no longer have to formally adopt a Paris-aligned transition plan as part of their due diligence obligations.
- More runway. Member states now have until July 2028 to transpose the directive, with companies given until July 2029 to comply.
- Less pressure flows downstream. Information requests to smaller suppliers further down the value chain have been scaled back.
Net effect: a smaller, later, lower-stakes version of the same core idea: large companies still have to identify and address human rights and environmental risks in their value chains.
Why procurement still has work to do
Three things haven’t changed, and they’re the ones that matter most for procurement:
- If you’re in scope, you’re still in scope. For the large enterprises the directive now targets, the due diligence obligation (identify, assess, mitigate, monitor, report) is unchanged in substance. Fewer companies have to do this, but those in scope still need to do it properly.
- Your customers may be in scope even if you aren’t. Plenty of mid-sized companies sit just under the new thresholds themselves but sell into large enterprises that are covered. Those customers will still push due-diligence questionnaires, code of conduct sign-offs, and audit rights down their supply chains, meaning procurement teams everywhere are still fielding these requests, albeit with less regulatory heat behind them.
- The underlying risk hasn’t gone away. A narrower law doesn’t make forced labor, unsafe working conditions, or environmental damage in a supply chain any less of a reputational and operational risk. Investors, customers, and NGOs are still watching.
In short: fewer companies face a legal mandate, but the operational playbook for procurement: supplier vetting, risk classification, ongoing monitoring, remediation planning, is exactly as relevant as it was before.
Where JAGGAER fits in
This is where a source-to-pay platform earns its keep. Rather than treating due diligence as a bolt-on compliance exercise, JAGGAER builds it into the procurement workflow itself:
Due diligence baked into onboarding, not bolted on after.
Supplier due diligence, compliance checks, and traceability are part of supplier onboarding rather than a separate, manual step, including deeper category-specific traceability (e.g., palm oil, cotton) through specialist data partners.
One place to see the whole picture.
A dedicated “supply chain due diligence” view sits alongside the supplier profile, performance history, spend data, and contracts you already track, so due-diligence status isn’t buried in a spreadsheet somewhere else.
Continuous monitoring, not a once-a-year checkbox.
Automated data collection and real-time compliance checks mean supplier risk status updates autonomously, rather than depending on an annual manual review cycle.
A live ESG data layer across sourcing and spend.
Supplier ESG data, including Scope 3 emissions, gets centralized so it can actually inform sourcing decisions, not just populate a report after the fact.
Network intelligence, not a cold start.
New strategic suppliers can be assessed against JAGGAER’s existing supplier network and external data feeds, so customers aren’t starting due diligence from zero every time they onboard someone new.
The takeaway
Omnibus I shrank the list of companies with a legal obligation under CSDDD, but it didn’t shrink the list of companies whose customers, investors, or reputations still expect responsible sourcing. For procurement teams navigating that gap, the goal isn’t just staying compliant with a narrower law. It’s building supply chain visibility that holds up regardless of where the regulatory line falls next.
Want to see how JAGGAER’s solutions can support? Talk to our team.
