Human Level joined the over 300 people who met in Brussels to discuss this question at the “Driving effective due diligence: Omnibus Unpacked” conference, co-organised by the Responsible Business Alliance and European People's Party (and MEP Axel Voss in particular).
The conference, held in Brussels on the 24 March, brought together representatives from companies and business associations, governments, the European Commission, human right due diligence (HRDD) experts and members of the European Parliament to discuss the impacts of the recently proposed EU Omnibus I simplification package on the Corporate Sustainability Due Diligence Directive (CSDDD).
HumanLevel’s Take:
Six key takeaways from the conference:
1. Simplification without deregulation. The general consensus in the room, captured by MEP Axel Voss’ opening address, was that the Omnibus proposal should balance the objectives of simplification and competitiveness with ensuring businesses do not profit from environmental destruction and human rights violations. Different stakeholders present voiced their intention to safeguard the CSDDD’s objectives, while ensuring companies do not face unnecessary burdens. The need for sustainability as a pre-requisite for competitiveness was highlighted by several additional speakers, including business representatives. In the words of Nokia’s Head of Tech Policy, “we believe that competitiveness and sustainability are two sides of the same coin.” Pedro Oliveira, Director of Legal Affairs at BusinessEurope, echoed this by saying that “sustainability is good business.”
2. Alignment with international standards as key for simplification. While different measures to balance the two objectives of the Omnibus’ proposal were mentioned, most panellists and speakers agreed with the idea that further alignment with international standards like the UN Guiding Principles and OECD Multinational Guidelines would be key to ensure that due diligence is both effective and manageable for companies. Responsible Business Alliance’s CEO, Rob Lederer, reinforced this by reminding the group that “we have over 20 years of experience doing this right.” Companies like BMW and Nokia shared how they have been implementing due diligence for over a decade, finding it valuable now that the law aims to level the playing field and help companies tackle the issues together. As Allan Jorgensen, Head of Centre for Responsible Business Conduct in the OECD, pointed out “the practice of risk-based due diligence approach is not new in practice but new in legislation,” which explains the current uncertainty voiced by businesses. At the same time, there are already a number of laws that take a value chain-approach to due diligence.
3. Risk-based due diligence in the value chain as both effective and efficient. There was broad consensus that a risk-based approach in the value chain (chain of activities) must be re-introduced, as it provides legal certainty and avoids the excessive obligations of the proposed Tier 1 approach. Several speakers shared how a Tier 1 scope reinforces misguided practices being seen in the implementation of the German Supply Chain Act (LkSG), such as over-assessing all direct suppliers and using long and non-specific SAQs—leading to the opposite of simplification. Mr. Lederer from the Responsible Business Alliance added that “the concept of plausible information would give companies less control of their due diligence beyond Tier 1,” making companies reactive instead of in the driver’s seat, as voiced by Marc Hodge from Shift. BMW’s Vice President for Sustainability Supply Chain, Nadine Philipp, echoed these views by saying that “it is very important for the company to focus its activities not only on the first tier but also on the root causes, to realty tackle the problems on the ground.”
4. The first in a ‘fleet of omnibuses.’ The European Commission representatives shared Omnibus I is seen as only the first of a “fleet ofOmnibuses” aiming to address the compliance burdens European companies face. Commissioner Ms. Amaryllis Verhoeven, Director of DG Grow, particularly recognised the need for harmonising due diligence beyond the CSDDD, a need also mentioned by business representatives who highlighted the challenges of complying with differing due diligence expectations across the Conflict Minerals Regulation,Deforestation Regulation, Batteries Regulation, Forced Labour Regulation, and the CSDDD. On this point, BMW’s Vice President for Sustainability Supply Chain shared that “the inconsistencies and incoherences between laws are also a key area of driving compliance work.”
5. Strong calls for practical guidance. One clear point of agreement across speakers was the belief that successful due diligence depends on good parameters and guidelines. This is key as it was clear from the examples shared that practices overburdening companies with information and assessment requirements stem from a misguided approach to due diligence. Pedro Oliveira from Business Europe emphasised the need for guidance from the European Commission on how to conduct risk-based human rights due diligence and, in particular, on how to map and identify risks. The EU Commission confirmed guidance on the final CSDDD text will be available by July 2026 – 2 years before the expected compliance date for CSDDD as proposed in the ‘Stop the Clock’ proposal.
6. Misguided interpretation and due diligence practices especially harm SMEs. Véronique Willems, Secretary General for SME United, shared that the biggest challenge small companies are facing, in relation to the implementation of due diligence expectations, has been the overwhelming amount of information requests and self-assessment questionnaires received from customers. This experience, stemming from a lack of risk-based approach to due diligence, could be further reinforced by the Omnibus I’s proposal to move away from risk-based due diligence. As a solution, speakers proposed for due diligence to be approached in a collaborative way, relying on business and industry organisations, and in closer collaboration with direct suppliers andSMEs – as is already integrated into the CSDDD law. A risk-based approach and alignment with international standards would also reduce burdens in proportion to companies’ size.
Thank you to the Responsible Business Alliance, Axel Voss Bart Devos, Robert Ledererand Greta Koch for organising this event and to the panellists and speakers: Lara Wolters, Nadine Philipp, Allan Lerberg Jørgensen, Pedro Oliveira, Dr. Kim Watts, Mark Hodge, Elise Cachin, Dr. Carsten Stender, Adrian Vazquez Lazara, Tyler Gillard, Kristin Pålsson, Nils Behrndt, Veronique Willems, Anna Cavazzini and Amaryllis Verhoeven.
