A new legal briefing by Frank Bold unpacks the new restrictions on information requests to business suppliers following the Omnibus 1 revisions to the CSRD and CSDDD, and explains the practical implications for companies.
As part of the sustainability reporting and due diligence requirements under the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), companies need to request sustainability-related information from their value chain partners.
The Omnibus 1 Directive introduced restrictions on how and when such information requests can be made in order to protect suppliers from disproportionate requests. These consist of the value chain cap under the CSRD and the limits on information requests under the CSDDD. For companies in scope of these directives, it is important to understand the new restrictions.
The publication also points to legal uncertainties resulting from the European Commission’s proposed Voluntary Standard when it comes to due diligence scoping, GHG data and climate risk information and proposes practical steps for companies to preserve effective supply chain management while remaining fully compliant with the caps.
If you have any questions about the briefing, please get in contact with Senior Policy Officer Julia Otten at julia.otten@frankbold.org.
The European Parliament has adopted the Corporate Sustainability Reporting Directive (CSRD), which clarifies transparency obligations for large companies operating in the EU on their sustainability impacts, risks, and opportunities. Pursuant to the CSRD, companies across all sectors will report against the European Sustainability Reporting Standards, which were developed by the European Financial Reporting Advisory Group (EFRAG), submitted to the European Commission and published on 22 November.
NGOs and civil society groups will only support an ambitious first set of sector-agnostic ESRS that closely builds on the EFRAG drafts adopted last November. They urge the Commission to follow EFRAG’s technical advice alongside 60+ companies and investors worth 651bn USD, and caution against making significant changes at this stage, as this would risk discrediting the process so far and undoing a good compromise.
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