FIEC-EIC ‚Top 10 Messages’ on Corporate Sustainability Due Diligence Directive

Following the adoption of the negotiating position by the EU Council – referred to as the ‘general approach’ – on the proposed Corporate Sustainability Due Diligence Directive (CSDDD) and the submission of the Draft Report of the European Parliament, Members of the Parliament’s Legal Committee (JURI) are currently discussing the more than 1,500 proposals for amendments.

Further to its previous positions and proposed amendments, published throughout the legislative process in July, September and November 2022, EIC and FIEC have prepared yet another Position Paper comprising our ‘Top 10 Messages’ for the ongoing negotiations in the European Parliament and for the upcoming trilogue in which they insist on the following key points:

1. Need for a new Impact Assessment on CSDDD

2. Adoption as a Regulation instead of a Directive

3. Focus on extra-EU activities

4. Adjustment of Personal Scope, including application to third country companies and their EU subsidiaries

5. Construction activities must not be categorised as ‘high risk’

6. Supply chain instead of value chain responsibility

7. Introduction of a Risk-based Approach

8. Legitimate interest required for submitting substantiated concerns

9. Sanctions not to be expanded to public procurement and export credits

10. Deletion of Directors’ duties of care

The FIEC-EIC Position Paper can be downloaded here