EU due diligence: CSDDD and the Forced Labour Regulation
The EU's 'Omnibus I' package, adopted in February 2026 and in force from 18 March, narrowed the CSDDD's scope, for non-EU companies to those with more than €1.5 billion of EU net turnover, and pushed full application back two years to 26 July 2029 (Shin & Kim). Few Korean companies are directly in scope, but in-scope EU customers will pass due-diligence information requests down to their suppliers. Separately, the EU Forced Labour Regulation applies from 14 December 2027 and bars products made with forced labour at any stage of the supply chain from being placed on, made available on or exported from the EU market.
How it unfolded.
- 2024-12-12
The EU Forced Labour Regulation (2024/3015) is published in the Official Journal; it applies from 14 December 2027. source ↗
- 2026-02-24
The EU Council adopts 'Omnibus I', the simplification package for the CSRD and CSDDD (published 26 February; in force 18 March). source ↗
- 2026-06-26
The European Commission publishes Forced Labour Regulation guidelines: the burden of proof lies mainly with authorities, but a company's non-cooperation can be grounds for a finding against it. source ↗
- 2027-07-26
The Commission is due to issue general due-diligence guidelines and guidance on voluntary model contract clauses. source ↗
- 2027-12-14
The Forced Labour Regulation starts to apply. source ↗
- 2029-07-26
The CSDDD applies in full (member states must transpose it by 26 July 2028). source ↗
What the markets are saying.
- 06.26 EU publishes Forced Labour Regulation guidelines
Daily closes, last six months. Source: Yahoo Finance; refreshed with each Global Watch edition (last update Oct 9, 2026, 6:37 AM KST). Indicators only, not investment advice.
Questions for your purchasing and risk teams
- Check whether your EU net turnover exceeds €1.5 billion (direct scope); if not, still prepare for due-diligence requests from in-scope EU customers.
- Prepare evidence for each supplier, covering human-rights and environmental risks with sources and dates, to answer customer questionnaires.
- Rank suppliers by risk (region, product) and look below tier 1 where risk is highest.
- Secure traceability records for products that will fall under the Forced Labour Regulation from 14 December 2027.
- Add due-diligence cooperation, information-sharing and corrective-action clauses to supplier contracts.
- Requests to business partners with fewer than 5,000 employees are limited to information not reasonably available elsewhere; negotiate the scope of excessive questionnaires.
- Assign someone to track follow-up dates, such as the Commission's due-diligence guidelines and model contract clause guidance due 26 July 2027.
What HELIOS does about it
- Continuous monitoring of local-language news on suppliers (labour or environmental incidents, lawsuits) and sanctions-list data, organised as sourced evidence.
- Ground Truth field verification, within the law, that supplier sites in Korea and Southeast Asia exist and are operating.
- Vision AI forensic checks of certificates, audit reports and site photos supplied by suppliers.
- Korean-language executive alerts on new EU guidance and changes in customer requirements.
As of 2026-10-05. Figures are as published by each source. Not legal or investment advice.
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