Chart of the Week #2026-34

Emerging Regulatory Risks to Energy Affordability and Security in the EU Worldwide Revenue of the Largest 500 Companies in Scope of the EU Corporate Sustainability Due Diligence Directive (CS3D), USD Billions

October 15, 2026 | Batt Odgerel

Key Points

  • The Corporate Sustainability Due Diligence Directive is designed to impose obligations on large businesses around the world, not just in the EU.
  • Although due diligence obligations for in-scope companies do not take effect until July 2029, EU member states must have implementing laws in place by July 2028.
  • The European Commission is now drafting implementation guidelines, which are due by July 2027.
  • CS3D violations could result in penalties of up to 3% of a company's global net turnover. Fines are based on the parent group's worldwide revenue, not just its sales in the EU.
  • The 500 largest corporate groups subject to CS3D generate approximately $27.9 trillion in combined annual revenue. This includes 123 US companies and 50 oil and gas companies, with the latter generating $4.9 trillion globally.

Annual worldwide revenue
Region
Sector
Basis for scope
Revenue figure
Number of Companies 0Revenue 0Oil & gas 0 0

Emerging Regulatory Risks to Energy Affordability and Security in the EU

The 500 groups analyzed in this chart were drawn from the CSDDD Datahub of the Centre for Research on Multinational Corporations (SOMO), a Netherlands-based nonprofit, which lists 1463 entries in scope of CS3D. The 500 groups were selected based on their revenue (in-scope oil and gas companies were included regardless of revenue) and have an estimated combined worldwide revenue of $27.9 trillion. Of these, 286 have a parent outside the EU, of which 123 are headquartered in the United States. The current analysis includes 50 oil and gas companies with the annual estimated turnover of $4.9 trillion.

  1. What’s CS3D?

    The European Union's Corporate Sustainability Due Diligence Directive (CSDDD or CS3D), adopted in 2024, requires large companies to identify, prevent and address adverse human rights and environmental impacts in their own operations, their subsidiaries and their chains of business partners. The Omnibus I amendments narrowed its scope, but it still entails oversize impact on businesses and households.

  2. CS3D Scope and Fines

    The CS3D applies to EU companies with more than 5000 employees and €1.5 billion in global turnover, and to non-EU companies with more than €1.5 billion in turnover made in the EU regardless of employee headcount. Fines are up to 3% of net worldwide turnover, calculated at the level of the parent company. For a group with $100 billion in revenue, that is up to $3 billion of its global turnover!

    The 2026 Omnibus amendments removed the EU-wide civil liability regime and the obligation to adopt a climate transition plan, and pushed compliance to July 26, 2029. Member states must transpose the changes into national law by July 26, 2028, and each sets its own penalty and liability rules within the directive's limits.

    The European Commission launched a public consultation on CS3D implementation guidelines in June 2026, with plans to adopt them by July 26, 2027. These initial guidelines will provide companies with practical guidance on conducting due diligence, including identifying risks, engaging stakeholders, and using data sources and digital tools.

  3. Potential Cost and Price Impacts

    Imported liquefied natural gas made up about 45% of EU gas imports in 2025. The United States supplied about 58% of that LNG and Qatar about 8%. U.S. exporters Cheniere Energy and Venture Global, and QatarEnergy, are among the groups in scope. Compliance costs and legal exposure for these suppliers can be priced into long-term contracts and passed through to gas and power prices for EU households and industry. Energy markets could be divided between suppliers that comply with the directive and those that sell in other markets, leaving EU buyers to pay a potentially hefty premium for their energy supply.

    In October 2025, US Secretary of Energy Chris Wright and Qatar's Minister of State for Energy Affairs Saad Sherida Al-Kaabi warned the EU that the directive "poses a significant risk to the affordability and reliability of critical energy supplies." Mr. Al-Kaabi said Qatar would stop supplying LNG to the EU unless the law was eased. The Omnibus amendments addressed several provisions they discussed but kept coverage of non-EU companies on the basis of their EU turnover.

  4. Unintended Effects: Trade Diversion?

    Companies facing fines have reason to reduce exposure by leaving suppliers and jurisdictions that are hard to document, rather than investing in improvements there. For the energy sector, this can concentrate supply among fewer sources, weakening the diversification and security of energy supply in Europe, while trade shifts to buyers that do not apply the same rules.

  5. How About Small Suppliers?

    The Omnibus amendments replace full supply chain mapping, which was in the original directive, with a risk-based scoping exercise and allow information requests to business partners with fewer than 5000 employees only where the information cannot be obtained by other means. However, large buyers manage liability through contracts, codes of conduct, questionnaires and audits, and these obligations reach suppliers regardless of their size. Many small and medium-sized companies lack the staff and capacity to meet those requirements, and some may lose customers because of the cost.

Watch This Space

In the coming months, EPRINC will hold a series of workshops and publish research on the impact of these regulations on households and businesses in the EU and the United States. If you would like to work with us, please reach out.