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Situation report for companies, Related topic

Supply chains, climate, border adjustment: what goes in 2026 and what stays

· Helfen statt Blockieren editorial team

In 2026 the EU substantially scaled back its supply chain law, Germany plans to abolish the reporting duty under its own act, and the carbon border adjustment entered its definitive phase. A situation report on what companies still have to do.

EU supply chain directive: smaller and later

Amending Directive (EU) 2026/470, published on 26 February 2026, raises the thresholds of the Corporate Sustainability Due Diligence Directive (CSDDD) to at least 5,000 employees and 1.5 billion euros in worldwide net turnover. Member states must transpose it by 26 July 2028, and it applies from 26 July 2029. The duty to adopt a climate transition plan is removed, as is the uniform EU civil liability regime. Companies may focus on the areas with the most likely and most severe risks; a full mapping of the supply chain is no longer required. The maximum fine falls from 5 to 3 percent of worldwide turnover.

German Supply Chain Act: duties stay, reporting to go

The government bill amending the German Supply Chain Due Diligence Act (printed paper 21/2474) had its first reading in the Bundestag on 16 January 2026 and was referred to committee. It abolishes the annual reporting duty retroactively to 1 January 2023 and limits fines to serious breaches. The due diligence duties themselves and seven years of documentation remain. Germany’s supervisory office BAFA stopped reviewing reports on 1 October 2025 and stopped accepting them on 7 November 2025. We have not found promulgation of the amending act in the sources available to us; the Federal Law Gazette is authoritative.

Carbon border adjustment: definitive phase since January

Since 1 January 2026 the Carbon Border Adjustment Mechanism (CBAM) has applied in full to imports of steel, aluminium, cement, fertilisers, hydrogen and electricity. Anyone importing less than 50 tonnes of these goods a year is exempt; the threshold does not apply to electricity and hydrogen (Regulation (EU) 2025/2083). Certificates go on sale from 1 February 2027, and the first annual declaration for 2026 is due by 30 September 2027. An extension to downstream products is still being negotiated.

What this means for companies

Fewer reports do not mean fewer checks. Anyone who knows their suppliers, their owners and the origin of inputs needs this data for sanctions screening anyway. According to the DIHK, 83 percent of the companies surveyed see EU rules such as supply chain duties and CBAM as a burden. This report is not legal advice for individual cases.

Sources

All online sources accessed on 3 November 2026.

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