CSDDD 2027 preparation: the 18-month roadmap

How companies in scope for CSDDD from July 2027 can prepare in the next 18 months. Priorities, milestones and tool implementation.

Pillar context

If your company is in CSDDD scope in 2027 (>5,000 employees, >€1.5B revenue), you have about 18 months to set up a working due diligence system. This is an operational roadmap, not theory.

Milestone 1 — Month 1-3: Scope and governance

Confirm in-scope status (employees × revenue thresholds)
Appoint a CSDDD owner (CSO, compliance director, or CFO)
Stakeholder map: legal, compliance, procurement, HR, sustainability, finance
Review existing NFRD/CSRD reporting — what is already documented?

Milestone 2 — Month 4-6: Risk identification

Map your full value chain (upstream + operations + downstream)
Identify "salient issues": highest impact × probability
Classify supplier tiers by risk (high/medium/low)
Start with top-100 suppliers by spend

Milestone 3 — Month 7-9: Integration and policy

Update supplier code of conduct
Integrate due diligence questions in RFP/RFQ
Training for procurement and compliance
Select and implement a due diligence management tool

Milestone 4 — Month 10-12: Mitigation and remediation

Audits for each high-risk supplier
Corrective action plans for identified issues
Grievance mechanism live
Start collecting remediation evidence

Milestone 5 — Month 13-15: Monitoring and communication

KPIs per salient issue
Internal quarterly reporting
Prep for external CSDDD report (first publication 2028)
Align with CSRD reporting

Milestone 6 — Month 16-18: Go-live preparation

Final audit of the entire system
Legal review
Communication plan for first formal publication (July 2027)
Supplier communication: everyone knows what is expected

Cost estimate

For a large company (>5,000 employees): €500K–2M one-off + €200K–800K per year. Major cost items:

External supplier audits (€30–50K per audit)
Tool license + implementation
FTE for CSDDD operations (2–4 FTE)

Why start now

18 months is tight. Companies that wait until Q3 2026 will miss the July 2027 deadline. The bottleneck is not tooling — it is the time needed to engage with suppliers.

PSRA's role

PSRA's supplier master data + LTSD workflow forms the base layer for CSDDD data gathering. If you already use PSRA for preferential origin, you have ~40% of CSDDD supplier data in hand. CSDDD-specific modules (sustainability audit storage, grievance channel) are added in 2027.

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Related downloads

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Related definitions

Audit trail: An audit trail records who did what, based on which source data, and with what decision logic.
BOM: A BOM is the bill of materials: the structured composition of a product.
Supplier declaration: A supplier declaration captures the origin information a supplier provides for supplied goods.
Customs declaration: A customs declaration is the formal notification to customs declaring goods for import, export, or transit, available in five procedure types.