The rules that apply to you, by market
The four markets this product reads
The short answerThis product reads one rule in full: Directive (EU) 2026/470, article by article. It also holds four related frameworks for a topical cross-check, and it names the regimes in the other three markets without stating them, because they are not held here. Scope level: European Union, plus a named reading for the United States, the United Kingdom and Australia.
Each market below names the frameworks that actually matter to a sustainability reporting lead, a group financial controller, a company secretary or a company lawyer, in market order: the United States, the European Union, the United Kingdom and Australia. Where a framework is held, it is read and linked. Where it is not held, the page names it and states no requirement from it (never a rule we cannot show you).
United States
The reporting regime for a United States listed group is named here, not read in full by this product.
| Framework | Read here |
|---|---|
| SEC Climate Disclosure Rule Named because a group with a United States listing meets a separate federal climate disclosure rule. | held and read |
| SSAE 18 - Attestation Standards (SOC Reporting) Named because an assurance provider working to United States attestation standards uses it. | held and read |
| PCAOB AS 2201 - Audit of Internal Control Over Financial Reporting (ICFR) Named because it governs the group auditor's internal control opinion where a United States listing is in play. | held and read |
European Union
The four frameworks this product reads are held here in full.
| Framework | Read here |
|---|---|
| CSRD The reporting directive the amending directive rewrites; held and read. | held and read |
| EU CSDDD (Directive (EU) 2024/1760) The due diligence directive Article 4 of the amendment rewrites; held and read. | held and read |
| EU Taxonomy Regulation Held because Article 8 taxonomy disclosures sit inside the sustainability statement. | held and read |
| German Supply Chain Due Diligence Act (LkSG) Held because a group operating in Germany meets it alongside the due diligence rules. | held and read |
United Kingdom
The United Kingdom regime is named, not held. This product does not state its text.
| Framework | Read here |
|---|---|
| UK climate-related financial disclosure requirements Named obligation for a group with a United Kingdom listing; the text is not held here, so no requirement is stated. | named, not held |
| UK Sustainability Reporting Standards Named as the standards in development for the United Kingdom; not held here and not stated. | named, not held |
Australia
The Australian standards are named, not read in full by this product.
| Framework | Read here |
|---|---|
| AASB S2 Climate-related Disclosures Named because a group with an Australian reporting obligation meets a separate climate disclosure standard. | held and read |
| AASB 18 Presentation and Disclosure in Financial Statements Named because it governs how the statement is presented where Australian reporting applies. | held and read |
The four held frameworks
These are kept in full and used only for a topical cross-check, never as an equivalence.
| Framework | Requirements held | Domains | Source |
|---|---|---|---|
| CSRD | 22 | 6 | see the standard |
| EU CSDDD (Directive (EU) 2024/1760) | 18 | 1 | see the standard |
| EU Taxonomy Regulation | 16 | 8 | see the standard |
| German Supply Chain Due Diligence Act (LkSG) | 11 | 7 | see the standard |
67 requirements between them, every one stated in our own words and cited to the framework it is held from.
Topical readings, never an equivalence
Each row joins a provision of the amending directive to a held requirement on the same topic, with a confidence and the reason. A topical reading is not a mapping and is not a statement that one satisfies the other.
| Amending provision | Held requirement on the same topic | Confidence | Why the two are read together |
|---|---|---|---|
| Directive (EU) 2026/470, Article 1(1) | German LkSG LkSG-Implementation-Roadmap-Org: LkSG Compliance Program Implementation - Organizational Roles, Tooling and Metrics | medium | Topical reading only, not an equivalence: Article 1(1) and this control share the topic audit, authority, management, rights, statutory. |
| Directive (EU) 2026/470, Article 1(1) | EU CSDDD Art 5(4): Due diligence: the eight actions and the retention of documentation | low | Topical reading only, not an equivalence: Article 1(1) and this control share the topic administrative, directive, management, rights. |
| Directive (EU) 2026/470, Article 1(2) | EU CSDDD Art 23: Authorised representative of third-country companies | high | Topical reading only, not an equivalence: Article 1(2) and this control share the topic competent, designation, give, member, name. |
| Directive (EU) 2026/470, Article 1(2) | EU CSDDD Art 16: Communicating: the annual statement | medium | Topical reading only, not an equivalence: Article 1(2) and this control share the topic directive, least, member, reporting, state. |
| Directive (EU) 2026/470, Article 1(3) | EU CSDDD Art 16: Communicating: the annual statement | medium | Topical reading only, not an equivalence: Article 1(3) and this control share the topic acts, adopt, commission, delegated, later. |
| Directive (EU) 2026/470, Article 1(3) | EU Taxonomy TAXO-Art.18: Minimum safeguards (Taxonomy Article 18) - OECD MNE + UN Guiding Principles + ILO + IBHR | medium | Topical reading only, not an equivalence: Article 1(3) and this control share the topic acts, adopt, commission, delegated, planning. |
| Directive (EU) 2026/470, Article 1(4) | German LkSG LkSG-EU-CSDDD-Coordination-Status: EU Corporate Sustainability Due Diligence Directive (CSDDD) Coordination + LkSG 2024-2025 Status | high | Topical reading only, not an equivalence: Article 1(4) and this control share the topic 2025, country, directive, identifying, january. |
| Directive (EU) 2026/470, Article 1(4) | EU CSDDD Art 16: Communicating: the annual statement | high | Topical reading only, not an equivalence: Article 1(4) and this control share the topic authority, country, directive, financial, information. |
| Directive (EU) 2026/470, Article 1(5) | EU CSDDD Art 16: Communicating: the annual statement | medium | Topical reading only, not an equivalence: Article 1(5) and this control share the topic acts, adopt, commission, delegated, period. |
| Directive (EU) 2026/470, Article 1(5) | EU Taxonomy TAXO-Art.18: Minimum safeguards (Taxonomy Article 18) - OECD MNE + UN Guiding Principles + ILO + IBHR | low | Topical reading only, not an equivalence: Article 1(5) and this control share the topic acts, adopt, commission, delegated. |
| Directive (EU) 2026/470, Article 2(1) | German LkSG LkSG-Sec9-Complaints-Sec10-Doc-Report: Section 9 Complaints Procedure + Section 10 Documentation + Annual Reporting | medium | Topical reading only, not an equivalence: Article 2(1) and this control share the topic employees, measures, reporting, rules, year. |
| Directive (EU) 2026/470, Article 2(1) | EU CSDDD Art 16: Communicating: the annual statement | low | Topical reading only, not an equivalence: Article 2(1) and this control share the topic balance, date, reporting, sheet. |
| Directive (EU) 2026/470, Article 2(2) | EU CSDDD Art 16: Communicating: the annual statement | high | Topical reading only, not an equivalence: Article 2(2) and this control share the topic article, commission, covered, delegated, least. |
| Directive (EU) 2026/470, Article 2(2) | EU Taxonomy TAXO-Art.19_19a: Technical screening criteria + Commission Delegated Acts (Taxonomy Article 19 + 19a) | medium | Topical reading only, not an equivalence: Article 2(2) and this control share the topic article, commission, delegated, reporting, review. |
| Directive (EU) 2026/470, Article 2(3) | CSRD CSRD-ESRS2-SBM: Strategy, business model and value chain | low | Topical reading only, not an equivalence: Article 2(3) and this control share the topic business, model, undertaking, value. |
| Directive (EU) 2026/470, Article 2(3) | EU CSDDD Art 5(4): Due diligence: the eight actions and the retention of documentation | low | Topical reading only, not an equivalence: Article 2(3) and this control share the topic business, management, resources, them. |
| Directive (EU) 2026/470, Article 2(4) | EU CSDDD Art 16: Communicating: the annual statement | high | Topical reading only, not an equivalence: Article 2(4) and this control share the topic directive, information, matters, reporting, standards. |
| Directive (EU) 2026/470, Article 2(4) | EU CSDDD Art 5(4): Due diligence: the eight actions and the retention of documentation | high | Topical reading only, not an equivalence: Article 2(4) and this control share the topic beyond, directive, impacts, information, into. |
| Directive (EU) 2026/470, Article 2(5) | CSRD CSRD-SCOPE: Scope of application and group reporting | high | Topical reading only, not an equivalence: Article 2(5) and this control share the topic basis, consolidated, group, information, management. |
| Directive (EU) 2026/470, Article 2(5) | EU Taxonomy TAXO-Art.8: Disclosure by financial and non-financial undertakings (Taxonomy Article 8) - the KPI regime | high | Topical reading only, not an equivalence: Article 2(5) and this control share the topic consolidated, include, information, reporting, statement. |
| Directive (EU) 2026/470, Article 2(6) | EU CSDDD Art 16: Communicating: the annual statement | medium | Topical reading only, not an equivalence: Article 2(6) and this control share the topic disclosures, financial, information, reporting, standards. |
| Directive (EU) 2026/470, Article 2(6) | EU CSDDD Art 8: Identifying and assessing actual and potential adverse impacts | medium | Topical reading only, not an equivalence: Article 2(6) and this control share the topic account, information, prioritise, relevant, take. |
| Directive (EU) 2026/470, Article 2(7) | EU CSDDD Art 16: Communicating: the annual statement | medium | Topical reading only, not an equivalence: Article 2(7) and this control share the topic article, directive, reporting, standards, sustainability. |
| Directive (EU) 2026/470, Article 2(7) | EU Taxonomy TAXO-Art.8: Disclosure by financial and non-financial undertakings (Taxonomy Article 8) - the KPI regime | medium | Topical reading only, not an equivalence: Article 2(7) and this control share the topic article, directive, reporting, sustainability, undertakings. |
Not legal advice; does not certify. A market with no held framework is named, never stated.