Sustainability2 credits

Determine CSDDD and WIVO scope — post Omnibus I, per entity type

Test whether your organisation falls under the supply chain due diligence duty of the CSDDD and the Dutch WIVO: EU undertakings on both employees and turnover, non-EU undertakings on their Union turnover, and franchisors via a separate threshold route. With borderline flagging, the climate transition plan band and the application dates that go with them.

csddd-wivo v1.0.0 · vintage 2026.1 · draft free
Example outcome
Scope outcomeIn scope
EU undertaking — 6,500 employees> 5,000
Net annual turnover — € 2,100M> € 1,500M
CSDDD/WIVO application date2029-07-26
sha256 a3f19c47e8b2d05f6c91a4e7d23b8f50…

Who it’s for

01Sustainability and ESG managers who must establish whether and when the due diligence duty will apply to their group.
02Legal counsel and compliance officers who want the scope determination recorded per entity following the Omnibus I amendments.
03Non-EU groups with Union turnover who want to know whether their EU turnover reaches the threshold, even without an EU establishment.

What the tool does

✓ Three entity routes: EU undertaking, non-EU undertaking and franchisor, each with its own test✓ Post-Omnibus I EU thresholds: more than 5,000 employees and more than € 1,500 million net annual turnover, both required✓ A non-EU test on Union turnover alone, with no employee threshold✓ Borderline flagging from 4,000 employees or € 1,200 million turnover, so you know when to start monitoring✓ A climate transition plan band for organisations between 1,000 and 5,000 employees with € 450 to € 1,500 million turnover✓ A timeline with the recorded dates: Omnibus I entry into force, the WIVO transposition deadline and the 26 July 2029 application date
01 — Form
Case and key figures — a handful of fields.
02 — Draft
Full outcome layout, free.
03 — Pay and receive
Via Mollie, VAT/VIES handled.
04 — Report
Certified PDF + public hash.

Why Omnibus I puts the scope question back on the table

Omnibus I raised the CSDDD thresholds sharply: from more than a thousand employees and € 450 million turnover to more than five thousand employees and € 1.5 billion. Organisations that were already preparing under the old regime may therefore fall outside the direct obligation — but not outside the practice: as a supplier to an undertaking that is in scope, the questions reach you anyway. The check distinguishes those two situations explicitly.

The route matters too: an EU undertaking must exceed both thresholds, a non-EU undertaking is tested on Union turnover alone and has no employee threshold at all. Franchisors fall under yet another set of thresholds. The check gives the outcome, the borderline flag and the climate transition plan band per situation, with the tool version and the dataset vintage all thresholds and dates come from — so a reassessment on growth or on a legislative change stays comparable.

Frequently asked questions about this tool

What does a “borderline” outcome mean?
That you do not meet the thresholds but sit close enough to keep watching them: more than 4,000 employees or more than € 1,200 million turnover. It is a signal from the tool itself, not a statutory category. On growth you can rerun the same calculation and set the two reports side by side.
Why doesn’t headcount count for a non-EU undertaking?
Because the test for non-EU undertakings looks only at Union turnover. The headcount is stated in the report but plays no part in the outcome on that route. For an EU undertaking both thresholds must be exceeded, and strictly: exactly at the threshold is not above it.
What happens if I leave EU turnover blank?
The test for a non-EU undertaking falls back on your worldwide turnover. That can overstate scope: a group with € 3 billion worldwide but limited EU turnover then comes out as in scope. The tool raises an explicit tip in that case to enter EU turnover after all — do so, or the outcome is not usable.
Do I get a scope outcome as a franchisor?
No. Franchisors fall under a separate threshold route — EU royalties above € 75 million combined with worldwide turnover above € 275 million — and the tool does not compute it. You get the route and its thresholds as the outcome, with a note that the source itself records those thresholds as still needing verification.
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