The CSDDD and the CSRD after Directive (EU) 2026/470: a missed opportunity for regulatory coherence

This paper argues that the CSRD and the original proposal for the CSDDD were conceived as complementary instruments within the EU sustainability framework. While the final text of the CSDDD had already reduced that complementarity, Directive (EU) 2026/470 further weakens the systemic connection between the two regimes. The Omnibus reform does not merely narrow the personal scope of both instruments. It also deepens their asymmetry by preserving divergent concepts of “value chain” and “chain of activities”, removing climate transition plans from the CSDDD and weakening the enforcement architecture. The result is a more fragmented sustainability framework, which generates legal uncertainty and constitutes a missed opportunity to build regulatory coherence between sustainability reporting and sustainability due diligence.