The law targets very large companies, but purchasing terms will carry its pressure much further.
A small Dutch supplier opens a contract-renewal email from its largest customer. Attached is a questionnaire about product origins, labour conditions, environmental risks, subcontractors and complaints. The customer also wants a signed declaration and the right to request supporting documents.
The supplier has eight employees. Nobody there considers the company part of a multinational sustainability regime. Yet the commercial question is immediate: can it answer honestly without delaying the renewal or accepting promises it cannot control?
That scene captures the practical importance of the assessment published by the Netherlands Authority for Consumers and Markets, ACM, on 1 October 2026. The proposed Wet Internationaal Verantwoord Ondernemen remains in preparation. It is not a new duty for every Dutch business. Its commercial effects may still travel down supply chains before the law starts applying.
The legal boundary matters
The Dutch bill is intended to implement Directive (EU) 2024/1760, the Corporate Sustainability Due Diligence Directive. Rijksoverheid currently describes its scope as companies with at least 5,000 employees and €1.5 billion in turnover. The Netherlands must transpose the directive by 26 July 2028. Companies within scope are expected to comply from 26 July 2029.
The legislative calendar records an internet consultation from 3 July to 2 August 2026. The proposal remains in preparation, before advice from the Council of State and parliamentary consideration. Government approval during 2027 is an expectation, not a completed legislative fact.
ACM’s assessment gives the bill a conditional green light. The regulator considers it capable of implementation and supervision if four conditions are met. Authorities must identify relevant companies from outside the EU. European guidance must make the open standards concrete. ACM needs enough capacity to set sensible priorities. European supervisors must also cooperate quickly and effectively.
Those conditions show that the final supervisory framework is still being built. Smaller companies should treat the proposal as a developing framework rather than a current statutory obligation. At the same time, the subject will reach many of them through commercial relationships.
The contract carries the pressure
Large companies will need information from the businesses that supply them. Procurement departments are likely to translate that need into onboarding questions, supplier standards, warranties, reporting clauses and audit rights.
A contractual declaration deserves more attention than a routine tick box. Once signed, its wording can create a commercial promise even when the supplier has no direct duty under the future Wivo. A broad assurance about every subcontractor, country of origin or labour condition may exceed what a small company can actually know.
This is where legal reading and business judgment meet. The founder must distinguish between three things: what the law directly requires, what the customer asks under the contract, and what the company can support with records. Treating those questions as interchangeable creates avoidable risk.
The right response is not to build a miniature compliance department. It is to understand the chain that matters to the company. Which suppliers support important revenue? Where do purchases, specifications and certificates sit? Who notices when a producer, route or subcontractor changes? What happens when documents conflict or a supplier refuses a reasonable question?
ACM says businesses under the future regime need not achieve perfection immediately, but they must take steps and build systems that prevent problems. For a smaller supplier, that points towards proportionate discipline: clear ownership, retrievable records, measured declarations and escalation when the facts no longer fit the promise.
Public claims already carry consequences
Separate legal pressure is already present in sustainability claims and labels. Stricter rules took effect on 27 September 2026, with ACM as supervisor. Generic environmental claims made without explanation face strict limits. A company’s own sustainability label also requires independent control.
These consumer-information rules and the future CSDDD framework are separate regimes. They meet at the same business weakness: language that travels further than the evidence behind it.
A wholesaler may describe a product range as responsible, ethical or green because a supplier once provided a certificate. Years later, the producer may have changed, the certificate may have expired, or the claim may cover more products than the document does. Marketing sees one sentence. Purchasing sees several suppliers. Administration sees invoices. Nobody sees the whole claim.
That fragmentation is a governance problem with a market price. A challenged statement can consume management time. A missing answer can slow a tender or renewal. New audit rights can add recurring work without adding revenue. When a customer expects substantial chain information, the supplier may need to reflect that work in its price, purchasing terms or service scope.
The supplier from the opening scene should resist two poor choices. One is refusing every request because the future law does not directly cover the company. The other is signing everything to protect the sale. A stronger position is calm and precise: confirm what is known, identify the supporting records, qualify what cannot be established, and agree how updates will be handled.
Responsibility starts with ordinary records
For most small businesses, the useful first step is modest. Select the suppliers, products or services most important to revenue and customer promises. Compare the contract, purchase history, product information and public wording. Then give one person responsibility for keeping that picture current.
This is not a demand for perfect visibility across the world. It is a demand for honesty about what the company knows, what it has checked and where its knowledge ends. Dutch business culture respects a clear answer more than an inflated promise, especially when the answer can be supported later.
The future Wivo is aimed at very large enterprises. Its first practical effect on smaller firms will often arrive through a buyer’s email, not an ACM letter. Companies that handle that email well will not be those with the finest sustainability language. They will be those that understand their contracts, their suppliers and the limits of their own assurance.
If customer due-diligence requests are changing your contracts, review what your business can document before making broader assurances.
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- UHT ontwerpwetsvoorstel Internationaal Verantwoord Ondernemen | ACM
- Overheid.nl Wetgevingskalender - Legislative status and national implementation route
- Rijksoverheid - Current CSDDD scope and revised timetable
- Autoriteit Consument en Markt - ACM supervisory preparation for international chain responsibility
- Autoriteit Consument en Markt - Current enforcement pressure on sustainability claims
- Ondernemersplein - Separate broad proposed duty concerning child labour
- Overheid.nl
