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Compliance

CS3D and CSRD: what the new European regulation concretely changes for your African teams in 2026

The Omnibus directive of March 18, 2026 redefines due diligence and ESG reporting. For your African operations, the stakes are concrete: audit the value chain, document employment conditions, demonstrate compliance.

Équipe juridique et ESG KernelÉquipe juridique et ESG Kernel
12 min
Key figures
March 18, 2026
Omnibus directive entry into force
1,000+
employees, CS3D threshold after Omnibus
€450M
EU revenue, CS3D threshold after Omnibus
July 2029
effective CS3D application start

On March 18, 2026, the Omnibus directive came into force, amending the CS3D (Corporate Sustainability Due Diligence Directive) and CSRD (Corporate Sustainability Reporting Directive). For many European companies with employees or suppliers in Africa, these two directives transform their obligations regarding human rights, working conditions, and ESG reporting. The stakes are concrete: auditing the value chain, documenting employment conditions, demonstrating compliance across extended supply chains.

Note on this English version. This article exists in a fully detailed French edition. The complete English translation by our editorial team is in progress and will replace this summary shortly.

Key takeaways

  • Scope after Omnibus. CS3D now applies to companies with more than 1,000 employees and more than €450M EU revenue. CSRD applies to large companies above 1,000 employees and €50M revenue, plus listed companies.
  • Effective application. CS3D effective application starts in July 2029, with national transposition due July 2028. CSRD reporting cycles begin earlier.
  • Value chain concept. Own activities, subsidiaries, direct business partners, and indirect ones when credible knowledge of negative impact exists.
  • Why African operations are scrutinized. Documented sectoral risks, information asymmetry, contractual practices at risk (disguised contractors), low public visibility historically.
  • Sanctions and reputation. Civil liability now governed by national law. Administrative fines remain. Reputational exposure via mandatory public reporting.
  • Operational implications. Regularize disguised contractors, audit your EOR chain, document employment conditions, extend group HR policies to Africa, deploy accessible grievance mechanisms.

How Kernel facilitates your CS3D and CSRD compliance

Kernel provides locally compliant employment contracts including ESG clauses, full administrative and social documentation exportable for audits, operational transparency without opaque intermediary chains, annual ESG reporting for clients, and a structured grievance mechanism independent of operational managers.

Going further

To structure your CS3D and CSRD compliance for African operations, contact the Kernel legal and ESG team. We offer a free audit of your current situation with a risk map and an action plan tailored to your scope.

Disclaimer: this article is for educational purposes and does not constitute legal advice. Last update: May 2026.

Main sources

  • Directive (EU) 2024/1760 (Corporate Sustainability Due Diligence Directive, CS3D)
  • Directive (EU) 2022/2464 (Corporate Sustainability Reporting Directive, CSRD)
  • Omnibus Directive I published in the OJEU on February 26, 2026, in force March 18, 2026
  • ESRS (European Sustainability Reporting Standards)
  • OECD Guidelines for Multinational Enterprises
  • UN Guiding Principles on Business and Human Rights
  • Norton Rose Fulbright, Linklaters, White & Case 2026 publications

Data and references consulted at the time of writing. Kernel does not reproduce verbatim quotes protected by copyright.

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