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Requirement · DD-04

Carry out an in-depth assessment of an indirect business partner where plausible information suggests an adverse impact there, or where an indirect structure is used to circumvent the direct-partner-only rule

Addressee Companies subject to due diligence duties under Directive (EU) 2024/1760Act COM(2025) 81, 2025/0045 (COD)Article Art. 4(4), inserting Art. 8(2a) of Directive (EU) 2024/1760Class Businesses

What changes

Companies must still reach indirect business partners, but now only when specific trigger conditions (plausible information, or circumvention) are met — narrower than a blanket chain-wide duty, but a real, newly-codified conditional obligation.

Prior rule vs new rule

Prior rule
Obligation

Prior wording not available in the source file.

New rule
Trigger

Plausible information suggesting an adverse impact at an indirect business-partner level, or an artificial arrangement circumventing the direct-partner assessment rule

Obligation

Carry out an in-depth assessment of an indirect business partner where plausible information suggests an adverse impact there, or where an indirect structure is used to circumvent the direct-partner-only rule

Who is affected

Addressee
Companies subject to due diligence duties under Directive (EU) 2024/1760
Class
Businesses
Sectors
No sector named — applies by size or activity
Applies
Once transposed by Member States (transposition due within 12 months of this Directive's entry into force)

Burden drivers

D1 — 1 of 7 marks fire on this provision.

Source text

Verbatim

Where a company has plausible information that suggests that adverse impacts at the level of the operations of an indirect business partner have arisen or may arise, it shall carry out an in-depth assessment. The company shall always carry out such an assessment where the indirect, rather than direct, nature of the relationship with the business partner is the result of an artificial arrangement that does not reflect economic reality but points to a circumvention of paragraph 2, point (b). Where the assessment confirms the likelihood or existence of the adverse impact, it is deemed to have been identified.

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