On 12 May, we hosted our webinar on the CSDDD as it now stands, led by Sandra Atler and Suvi Kuusi. Here is what we covered.
Simplified on paper. Substantive in practice.
The Omnibus revision was presented as simplification. In reality, several changes make it harder to ensure people affected by business operations have meaningful protection.
The key amendments:
→ Civil liability: EU harmonised regime removed and rules now vary by Member State, often depending on where harm occurred
→ Stakeholders: Definition narrowed, removing consumers, civil society organisations and human rights institutions – reducing the voices of those most affected
→ Climate transition plans: Obligation to adopt and implement a plan removed entirely
→ Monitoring: Reduced from annually to every 5 years, though annual CSRD reporting remains
→ Penalties: Maximum cap reduced from 5% to 3% of global net turnover
→ Scope: Thresholds raised to 5,000 employees and €1.5 billion turnover meaning around 70% of previously covered companies are now out of scope
Out of scope is not off the hook.
In Sweden, around 63 corporate groups remain in scope; in Finland, around 21. The due diligence process remains a two-step approach; a scoping exercise based on reasonably available information, followed by an in-depth assessment focused on where adverse impacts on people are most likely and most severe. Companies that supply to or partner with in-scope businesses will still face expectations and information requests.
Awareness is there. Impact focus is not.
In Finland, key challenges are around risk-based prioritisation, value chain visibility and stakeholder engagement. In Sweden, we see policy foundations in place but a reactive approach, with a tendency to focus on process over outcomes for people. Across both countries: the right internal functions are not always engaged, and the business case for due diligence is still being made.
From understanding to practice
Watch the recording below and consider joining our upcoming course in the Corporate Sustainability Due Diligence Directive this autumn or next spring, read more here.
Or reach out directly at www.enact.se/connect