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.
This legal briefing provides a detailed overview of the purpose, requirements, timeline, and most importantly, key interactions between different sustainability laws that will apply to companies operating in the European Union.
Speech by Filip Gregor at the public hearing on Reporting Obligations, held by the European Parliament's Committee on Legal Affairs on 13th May 2025
Whilst the European Parliament and the Council are in the midst of analysing and debating the Omnibus Simplification Package, we suggest our key changes for the co-legislators to implement to ensure that the CSRD is respected.
