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ARTICLE · 30 OCTOBER 2026

ACM Gives The Green Light To The Dutch CSDDD Implementation, With Four Strings Attached

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The Dutch Authority for Consumers and Markets has published its feasibility assessment of the Netherlands' implementation of the Corporate Sustainability Due Diligence Directive, identifying four critical conditions for effective enforcement. The ACM's analysis reveals how supervision will operate in practice, including its risk-based approach, handling of cross-border enforcement challenges, and reliance on EU guidance for interpreting open-ended standards.

NetherlandsCorporate/Commercial Law

As part of the implementation process of the CSDDD, the Dutch Authority for Consumers and Markets published its feasibility and enforceability assessment of the Dutch implementation of the CSDDD. The ACM concludes that the Dutch implementation is feasible provided four conditions are met, and it flags several practical issues that will shape how supervision takes place in the years ahead. This document offers some useful insight into where enforcement of the CSDDD is heading in practice.

On 17 September 2026, the Dutch Authority for Consumers and Markets (Dutch acronym: ACM) issued its feasibility and enforceability assessment of the draft bill on International Responsible Business Conduct (Dutch acronym: WIVO), which implements the Corporate Sustainability Due Diligence Directive (CSDDD) into Dutch law. This assessment was recently published. The Dutch implementation of the CSDDD designates the ACM as the supervisory authority responsible for monitoring compliance with the CSDDD.

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