Executive summary
The European Commission’s Omnibus proposal, intended to simplify and streamline key sustainability legislations, would in its current form fragment legal certainty, increase burdens on business, and dilute alignment with the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises (OECD Guidelines).
This article draws on our experience as practitioners working with companies to implement human rights and environmental due diligence (HREDD). It shows how the Omnibus proposal would disrupt company due diligence practices, undermine climate credibility, and create inefficiencies across the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD).
We instead propose concrete and practical approaches to achieving simplification and supporting companies in meeting their business realities.
Key concerns and recommendations include:
- The weakening of the risk-based approach by introducing requirements focused primarily on tier-1 would shift efforts away from where they matter most. Thus introducing compliance burdens, without creating value for business.
Recommendation: Strengthen and clarify the risk-based approach by providing practical, coherent guidance that allows companies to prioritize risks across their entire value chain.
- The tier-1 focus would incentivise companies to run parallel systems—one for legal compliance with the CSDDD, and one to meet other legal requirements and standards as well as investor and customer expectations.
Recommendation: Establish a single, cohesive due diligence process aligned with international standards to reduce duplication and costs.
- The focus on tier-1 relationships risks disproportionately burdening European SMEs, and restrictions on the information in-scope companies can request from SMEs may lead to their exclusion, as buyers struggle to obtain sufficient data.
Recommendation: Implement tailored, risk-based, and sector-specific approaches that prioritize capacity-building and joint solutions for SMEs rather than one-size fits all questionnaires and contractual risk-shifting.
- Mandated cascading of due diligence obligations to all suppliers can push disproportionate responsibilities onto SMEs, encouraging box-ticking rather than meaningful risk management.
Recommendation: Require companies to use cascading on a risk-based basis and in a way that doesn’t shift risk unfairly, giving companies the flexibility to tailor their approach to their supply chains.
- The removal of uniform liability rules undermines legal clarity and increases litigation risk through conflicting national regimes.
Recommendation: Retain a uniform civil liability standard to ensure legal certainty and create a level playing field for all companies.
- Climate transition plans need enforceable obligations to be effective—disclosure alone will not drive implementation. They also need to be aligned with the Paris agreement.
Recommendation: Reinstate the obligation to implement climate transition plans to ensure credibility and effectiveness, and retain reference to the Paris agreement and 1.5 degrees target.
- Digital tools, AI, and assurance processes must support — not replace — judgement, prioritisation, and stakeholder engagement.
Recommendation: Invest in the development of common, open-access digital tools and AI solutions aligned with international standards and risk-based approaches, and provide clear guidance on their appropriate use as supportive, not primary, mechanisms for due diligence.
- Treating reporting as a separate process rather than as an outcome of due diligence creates duplication and unnecessary administrative burdens.
Recommendation: Provide guidance on how the CSDDD and CSRD can be carried out as a single, integrated process, streamlining risk analysis and materiality assessment to avoid duplication and reduce compliance costs.
This article concludes that simplification is best achieved through smarter regulation: coherent, risk-based, and aligned with business realities — not deregulation. Consistent guidance and shared tools are the real keys to reducing cost, increasing impact and strengthening EU competitiveness.
A Step Backward in the Name of Simplification
With its Omnibus proposal, the European Commission has opened Pandora’s box. Rather than simplifying sustainability legislation, the proposed amendments would deregulate it. The Commission’s proposal — alongside the Council’s position and the draft report by Rapporteur Warborn — will undermine legal certainty and move away from international standards. Instead of solving implementation challenges, the suggestions echo mistakes already seen in jurisdictions with mandatory due diligence legislation.
The uncertainty created by the Omnibus proposal has already had a chilling effect. Many companies are pausing planned investments in due diligence and reporting due to pushback on budgets and resources allocated to the CSDDD and CSRD. As a result, necessary investments are being delayed.
From a competitiveness perspective, the Omnibus proposal penalises European companies that have taken early action, while rewarding laggards and third-country competitors . This undermines leadership and stifles innovation. Yet, the external pressures remain: companies still need to meet their own commitments, respond to investor scrutiny, and fulfill customer expectations. By weakening alignment with the UNGPs and the OECD Guidelines, the proposal adds complexity for companies, while providing little value.
Simplification should come through greater coherence with international standards, especially in relation to terminology, definitions, and scope, as well as clear guidance on how to implement EU sustainability laws (CSDDD, CSRD and the Deforestation, Battery, Forced Labour and Taxonomy regulations) coherently. Instead, the proposed changes would raise costs, increase burdens, and undermine the effectiveness of due diligence.
Increased Costs and Burdens of the Tier-1 Approach
For most companies, the most severe human rights and environmental impacts occur beyond their tier-1 business relationships. This is acknowledged in the Commission’s own staff working document accompanying the Omnibus proposal. By imposing a legal obligation to focus on tier-1 business relationships, the proposal would force companies to divert resources toward relationships that generally carry lower risk. This would deviate from established, risk-based practices. Such an approach would furthermore incentivise them, due to business realities, to run two parallel due diligence systems — one aligned with international standards and investor expectations, and another built solely for legal compliance. This duplication increases costs without creating business value.
Understanding supply chains beyond tier-1 is already required under other laws and standards. These include the Deforestation, Battery, Forced Labour and Taxonomy regulations, as well as sanction regimes and international standards such as the OECD Guidelines and the UNGPs. These international standards are increasingly applied by companies as part of their own internal commitments, as well as by courts when establishing company obligations, based on expected standards of conduct. Additionally, having visibility and knowledge of key supply chains is essential in building resilience and business continuity, which became apparent for many companies during the Covid-19 pandemic.
A limited CSDDD scope will not eliminate these pressures; it will simply add cost and complexity by mandating a compliance-oriented process disconnected from business realities. Moreover, the cost and benefits of implementing meaningful due diligence need to be put in relation to the risk of inaction, and the potential legal, financial, operational and reputational consequences facing companies involved in adverse impacts. Even for companies that have yet to start implementing sustainability due diligence, a risk-based, tier-n approach is more cost-effective and simpler, as it allows resources to be targeted where risks are most significant.
Experience from the German Supply Chain Act also illustrates the unintended consequences of a tier-1 approach. The law has often been misinterpreted as limiting due diligence to direct suppliers, leading to excessive bureaucracy — especially for SMEs. Many companies resort to standardized information requests to all direct suppliers, regardless of risk. Resources are drained by inefficient processes, limiting companies’ abilities to address more severe impacts further upstream. Companies report that the tier-1 focus creates ineffective, resource-heavy procedures and hinders proactive risk management. The result is a shift toward formalistic, box-ticking exercises that add burden but little value.
By contrast, the KPMG Review Report on the Norwegian Transparency Act — commissioned by the Ministry of Children and Families — found that a risk-based approach without a tier-1 limitation is more efficient and less burdensome. A recent study by the Norwegian Government confirms this view. This view is also supported by other analyses, including a comparative assessment of Germany and Norway.
Strengthening and Clarifying the Risk-Based Approach
A well-functioning risk-based approach lies at the heart of effective and efficient sustainability due diligence. It aligns with international standards, reflects current company practice, and enables businesses to focus resources where the most severe risks are found.
To achieve genuine simplification, the directive must therefore support and enable companies to prioritize risks across the value chain, using reasonably available information. This requires practical, coherent guidance — not arbitrary constraints. The risk-based approach should be understood as a standard of conduct and means which obliges companies to continuously improve their practices, not as an obligation to achieve full traceability or perfect knowledge from the outset. Companies should be expected to build their understanding progressively, starting with the most severe and likely impacts and using a mix of tools and methods suited to their business model and operating context, including geographies and activities. Companies that already apply the UNGPs and OECD Guidelines follow this approach—not because they are required to, but because it works.
In terms of effective implementation and demonstrating compliance, the CSDDD should reflect that sustainability due diligence is not a one-size-fits-all model. Company obligations must be tailored to the nature of the risks and where they occur in the value chain. While audits may be appropriate in some contexts, other situations may call for awareness-raising, capacity building, or addressing risks through e.g., product design. The CSDDD should allow for this flexibility. Implementation guidance should reinforce this by providing examples of risk-appropriate measures, supported by open-source information on common sector-specific risks.This would reduce duplicative efforts across companies and enable smarter prioritization.
Guidance is also needed to explain how the risk-based approach is applied consistently. For instance, value chain mapping under Article 8 of the CSDDD should not be interpreted as requiring traceability across all value chains independent of risk, which would be burdensome and ineffective. Instead, it should help companies identify which value chains carry the highest impacts, and where due diligence efforts should be concentrated. These value chains could then, in individual cases, be (partially) traced, if that helps address impacts. Likewise, Articles 10 and 11 of the CSDDD should be understood to permit targeted action plans addressing the most severe impacts, not comprehensive plans for every supplier or impact. Explaining the coherent implementation of the risk-based approach across the directive and other EU sustainability laws is essential in reducing burdens and costs and ensuring that company efforts deliver meaningful outcomes.
Getting It Right for SMEs
Strengthening and clarifying the risk-based approach is also essential for the many SMEs that will be indirectly affected. While SMEs are not in scope, they form a critical part of global value chains and are already experiencing due diligence demands from large buyers. For sustainability due diligence to be effective, it must meaningfully include SMEs and acknowledge their role in global value chains. But inclusion must come with realism: SMEs generally have fewer resources and limited capacity compared to large MNEs, but may also have closer relationships with suppliers, enabling more direct, high-quality due diligence.
Effective engagement with SMEs therefore requires tailored, risk-based, and sector-specific approaches that prioritise capacity-building and joint solutions over generic questionnaires and contractual risk-shifting. However, what we see in the Omnibus proposal is the opposite.
Through the Omnibus proposal’s focus on tier-1 relationships, European SME suppliers would be disproportionately affected by the CSDDD, as they are more likely to serve as direct suppliers to European companies than SMEs in third countries—a risk the European Commission itself acknowledges in the accompanying documents. At the same time, the Omnibus proposal’s restriction on in-scope companies from requesting targeted, meaningful information from SMEs and small mid-caps could unintentionally lead to their exclusion from procurement processes and contracts, simply because buyers are unable to obtain sufficient information. This limited scope in the CSDDD will not satisfy existing investor and customer demands— which are increasingly based on international standards—and thus enhance the risk profile of SMEs. What SMEs need is not carve-outs, but targeted support and flexibility to meet sustainability requirements without being pushed out of value chains.
If the limitation on what information can be requested is to be retained, a better compromise would be to use the Listed Small and Medium-sized Enterprises (LSME) reporting standard as the basis. Unlike the Voluntary Standard for Unlisted Micro, Small, and Medium-sized Entities (VSME), the LSME includes more substantive content on material sustainability impacts, making it a more meaningful foundation. To reduce burdens and costs and increase relevance, the LSME should also be adapted over time to reflect sector-specific risks, enabling SMEs to focus on disclosing information that is directly relevant to their operations. However, in high-risk sectors it must still be possible for buyers to request additional, targeted information from SMEs beyond what is currently included in the LSME.
The Omnibus proposal also suggests requiring companies to use contractual cascading to pass on responsibilities to all suppliers. In practice, this risks pushing obligations onto SMEs without considering their capacity to manage risks. Instead of simplifying due diligence, this approach increases burdens and costs and creates incentives for box-ticking rather than meaningful engagement. Companies should instead be required to use cascading on a risk-based basis and in a non risk-shifting way. The original CSDDD text strikes a better balance, offering companies the flexibility to tailor their approach to their own supply chains.
To reduce burdens and costs, accompanying guidance should also clarify that buyers can accept equivalent and aligned due diligence measures already in place at supplier level — such as questionnaires, reports, codes of conduct, grievance mechanisms, or action plans — provided they meet CSDDD requirements. Requiring all suppliers to respond or to adopt buyer-specific systems creates duplication and inefficiencies, particularly for SMEs. Instead, companies should be encouraged to align measures, including questionnaires and contractual terms, through standardised industry initiatives, streamlining expectations and supporting more consistent implementation across value chains.
In terms of shared responsibility in the form of responsible contracting, the original text of the CSDDD recognises this need and rightly prevents large companies from outsourcing responsibilities to SMEs or enforcing requirements without considering support measures.
Practical Support for Companies of All Sizes
To ensure consistency and reduce duplication, the European Commission—together with Member States—should develop a shared suite of guidance, templates, tools, and open-source data to support implementation of the CSDDD. This should be done centrally at EU level, rather than leaving it to individual Member States, in order to prevent fragmentation and eliminate the need for companies to navigate divergent national approaches.
Such a one-stop-shop would allow buyers to direct SMEs and other suppliers to open-access resources, helping them meet due diligence requirements without needing to reinvent the wheel. This would significantly ease the burden and costs on both large and small companies, enabling them to focus on implementation and prevent fragmentation.
Support should be integrated across company sizes — there is no need to have separate tools for SMEs and in-scope companies. Many tools will serve both, especially when grounded in sector-specific risk information and aligned with existing international standards.
High-quality, openly available resources already exist. Examples include:
- UN Global Compact’s Business and Human Rights Navigator,
- German Helpdesk on Business and Human Rights,
- Swedish Regions’ Supplier Due Diligence Guidance,
- CSR Risk Check by MVO Nederland.
The Commission should first assess and consolidate what support already exists, create a user-friendly central database, and conduct a practitioner-led gap analysis to identify what is still missing. Funding should then be allocated to close these gaps. Examples could include easily accessible data on living wage levels globally, value chain mappings and risk assessments for critical high-risk products, and standard templates for sector-specific questionnaires.
The support should include model contractual clauses, including sector-specific examples, that reflect responsible contracting principles. These would help streamline buyer-supplier relationships and establish more coherent industry practice across the EU.
Strengthening Meaningful Stakeholder Engagement
Practical guidance is also needed to clarify what meaningful stakeholder engagement entails and how the scope differs between a company’s operations and its value chain. While the aim should always be to seek input from potentially affected stakeholders, primarily workers and affected communities, a company’s access to such groups will vary depending on where the impacts occur — within its operations or further upstream or downstream.
The original text of the CSDDD acknowledges this complexity. It recognises that companies cannot engage with all potentially affected stakeholders across their entire value chain. This is why the risk-based approach must be preserved: it helps companies determine which stakeholders to prioritise, and where in their value chains engagement is most needed. It also allows companies to work with credible proxies and legitimate representatives—such as trade unions, NGOs, and national human rights institutions—when direct access is limited.
By contrast, the Omnibus proposal’s revised definition of “stakeholder” risks narrowing the scope of legitimate engagement. It could furthermore disincentivise companies from working with trusted intermediaries who often serve as vital conduits to workers and affected communities. This would weaken — not strengthen — the ability of companies to partner meaningfully in tackling human rights and environmental challenges.
Monitoring That Reflects a Changing Risk Landscape
The regularity of monitoring should reflect the dynamic nature of global risks and business environments. A fixed five-year interval for assessing the effectiveness of due diligence measures, as suggested in the Omnibus proposal, is out of step with today’s rapidly evolving realities. Just five years ago, global democratic decline had not yet reached current levels, Russia had not invaded Ukraine, the COVID-19 pandemic was in its early stages, and many believed the world had peaked in greenhouse gas emissions. Each of these developments has had profound and lasting impacts on people, ecosystems, and business operations and required businesses to analyse the adequateness of their HREDD and adapt it.
To remain effective, companies must be encouraged to monitor and adapt their due diligence efforts regularly, based on emerging risks and material changes in their operating environments. Tying effectiveness reviews to an arbitrary five-year cycle risks institutionalising inertia. Even if companies are permitted to review more frequently, the signaling effect may lead many to deprioritise meaningful, responsive monitoring.
A more appropriate approach would be to require periodic reviews at least every two to three years, and in response to significant contextual changes. However, it is essential to clarify that these provisions do not suggest that due diligence is a one-off or cyclical event. Due diligence is an ongoing standard of conduct, meaning that continuous risk assessments and tracking of effectiveness of actions taken are core obligations — not optional add-ons. The CSDDD should therefore be clarified to refer to the periodic review of the effectiveness of a company’s due diligence system — not the frequency of due diligence activities themselves.
The Role of AI and Digital Tools in Due Diligence
Digital tools and AI solutions can play a valuable role in helping companies scale up and streamline their sustainability due diligence efforts. However, the current market offers limited tools that truly meet company needs, including their legal obligations. Many existing platforms divert resources to costly, one-size-fits-all systems that prioritise automation over substance. This is particularly evident in generic questionnaires—often focused on tier-1 suppliers—that rely on simplistic yes/no answers (e.g. “Do you comply with all laws?”), adding little value while increasing compliance costs for both buyers and suppliers.
To move forward, the Commission and Member States should invest in the development of common, open-access digital tools and AI solutions that are aligned with international standards and adapted to risk-based approaches across sectors and supply chain tiers. They could, for instance, support the enhancement of the existing CSR Risk Check by adding visualisations of typical production stages, associated risks, and standardised questionnaire templates to facilitate consistent questions about such risks.
At the same time, it is essential to recognise the limits of automation. Due diligence is not a task to be outsourced — it is a standard of conduct that must be embedded in how a company operates. While IT and AI tools can support tasks like risk screening, compliance checks, and data analysis, their output should only be used as input—companies still need to apply their own judgment. This includes understanding root causes, developing a theory of change, engaging directly with affected stakeholders, and taking action on the ground. Automation can assist, but never replace, meaningful due diligence. The German Helpdesk for Business and Human Rights recently published guidance on this point.
Making Climate Transition Plans Enforceable
An essential aspect of sustainability due diligence is the need for clear and enforceable legal obligations to implement climate transition plans. Under the CSDDD, such obligations are critical for enabling reliable risk assessments and informed investment decisions—an approach supported by the European Central Bank and other financial institutions.
Without enforceable implementation requirements, transition plans risk becoming empty promises, undermining market confidence and weakening the credibility of corporate climate commitments. Disclosure obligations under the CSRD alone are not enough to close the implementation gap. Removing implementation requirements could also create a false sense of security for companies. Failing to carry out the actions described in a climate plan may well constitute prohibited greenwashing under EU competition law.
Robust transition planning is a practical tool for companies to structure, operationalise, and track their strategies for aligning with a low-carbon economy. It also strengthens corporate resilience by embedding climate risk into business strategy and governance.
To ensure credibility and effectiveness, the obligation to implement climate transition plans must be reinstated. Without it, the CSDDD risks leaving a critical dimension of corporate sustainability due diligence—climate change mitigation—unaddressed.
Retaining a Uniform Civil Liability Standard
To ensure legal clarity across the Single Market, the proposed amendments to the civil liability provisions should be rejected. The Omnibus proposal would eliminate the uniform cause of action currently set out in the CSDDD, removing the clear standard that companies are only liable for harm if it results from a failure to meet their due diligence obligations.
While this change may appear to reduce legal exposure for companies, in practice it would push liability questions into national legal systems, fragmenting the legal landscape instead of limiting them to the CSDDD scope—. Companies would face claims across all different national civil liability regimes in the world, with courts potentially applying hundreds of foreign legal frameworks under the Rome II Regulation—because it in most cases defers to the law of the place where harm occurred. This would directly contradict the objective of simplification and legal certainty.
The original CSDDD strikes a balanced approach: it establishes fault-based liability, excludes responsibility for harms caused by third parties, and protects companies that have appropriately deprioritised impacts. This approach provides a predictable legal framework while still holding companies accountable for failing to carry out due diligence.
Maintaining a uniform liability standard is also key to ensuring that third-country companies operating in the EU are held to the same obligations as EU-based businesses — creating a level playing field. Ultimately, the most effective way for companies to manage liability risk remains the same: to carry out meaningful, risk-based due diligence in line with the directive.
Aligning CSDDD and CSRD into A Single, Streamlined Process
The CSDDD and CSRD are complementary and interconnected. Rather than treating sustainability due diligence and reporting as separate exercises, companies should be supported in implementing them as a single, coherent process. The European Sustainability Reporting Standard (ESRS) already acknowledges this by stating that: “the outcome of the undertaking’s sustainability due diligence process informs the undertaking’s assessment of its material impacts, risks and opportunities.” In other words, conducting due diligence under the CSDDD generates the data needed for reporting under the CSRD, and the required risk and materiality assessments under both directives can therefore be streamlined.
This alignment is not yet widely understood, either by companies or by external advisors and auditors. As a result, companies often invest in parallel and resource-heavy data collection efforts instead of integrating due diligence and reporting. Addressing this misunderstanding through guidance and implementation support would significantly reduce compliance costs.
Crucially, both the CSDDD and CSRD rely on prioritisation. Companies are not expected to report on all data points under the ESRS, but only those deemed material. Similarly, the CSDDD allows companies to focus their efforts where risks are most severe and most likely to occur. Clarifying this shared principle would help companies avoid over-reporting and help streamline risk analysis, and materiality and indicator assessment. The goal should be having one coherent and synergetic process that fulfills all requirements.
Finally, the Commission and EFRAG should provide guidance on how risk assessments under the CSDDD and the double materiality assessment under the CSRD can be carried out as a single, integrated process. This would avoid duplication and reinforce the role of due diligence as the foundation for meaningful, cost-effective reporting.
Simplifying the European Sustainability Reporting Standards
In an effort to simplify, the EFRAG ESRS Exposure Drafts have collapsed sub-sub-topics into sub-topics, but the structure of the social topics still needs rethinking. There are also still overlapping requirements. Core elements — such as policies and channels to raise concerns — are repeated across sections, even though they belong to a single process.
A key challenge lies in the widespread misinterpretation and rigid application of the ESRS framework. Many companies follow overly complex guidance that overlooks the principle of prioritisation, leading to excessive, resource-heavy reporting that offers limited value to users of sustainability reports. Moving toward sector-specific standards that clearly define relevant material risks would enable companies to concentrate on the most significant issues without repetitive or generic assessments. Such sector-focused guidance would not only streamline reporting but also better align with the risk-based approach central to the CSDDD.
The emphasis on quantitative disclosure has also added to the problem. While quantitative indicators can be helpful, they often incentivise checkbox-style data collection without improving understanding or outcomes. Qualitative narratives, on the other hand, allow companies to explain their approach and provide context for their sustainability efforts. Encouraging a more balanced approach between quantitative and qualitative disclosures would reduce costs while enhancing the usefulness and credibility of sustainability reports.
To address these issues, the Commission should prioritise practical implementation guidance that supports companies in streamlining their ESRS disclosures. This guidance ought to include predefined, sector-specific material topics that companies may deviate from, if justified, supported by standardised questionnaires. Additionally, it should provide clear examples of how to report on integrated due diligence systems and narrative disclosures. By reducing duplication and emphasizing meaningful insights over data volume, such guidance will enable more straightforward, efficient, and impactful sustainability reporting.
Improving Assurance to Reduce Compliance Burdens
Assurance plays an important role in improving the quality and reliability of sustainability disclosures. However, companies are increasingly experiencing assurance processes as burdensome, inflexible, and inconsistent. A lack of clear guidance has left the interpretation of assurance requirements up to individual auditing firms, resulting in costly and often misaligned assurance approaches. Instead of reinforcing trust, they add red tape.
To reduce these burdens, the Commission should prioritise the development of clear assurance guidance. This guidance should be proportionate, risk-based, and sector-specific—moving away from one-size-fits-all models and tick-box auditing practices. Auditors should be encouraged to understand the context of a company’s operations and supply chains, including how prioritisation and risk-based due diligence are applied.
Capacity-building of auditors is also essential. Many assurance or certification providers lack the experience and frameworks needed to meaningfully evaluate sustainability due diligence. Phasing in more robust assurance requirements over time — coupled with targeted training — would improve consistency while avoiding immediate capacity bottlenecks.
Assurance guidance should also be aligned with sector-specific materiality expectations. Companies should be required to report on risks relevant to their sector, unless they can reasonably explain why those risks are not applicable. This approach would streamline assurance procedures while preserving flexibility and allowing for justified deviations.
The Way Forward
The CSDDD has the potential to become a cornerstone of sustainable business conduct in the EU and beyond. But to realise that potential, the directive must remain aligned with international standards and company realities. The Omnibus proposal risks undermining this by replacing clarity with complexity, and simplification with fragmentation.
Simplification is not achieved by narrowing scope or eliminating core provisions. It is achieved by providing companies with clear guidance and practical tools — enabling them to focus efforts where they matter most. A risk-based approach, embedded consistently across the directive, is not only the most effective way to address adverse impacts — it is also the most efficient.
Rather than incentivizing companies to run parallel systems — one for legal compliance and another to meet their own commitments and investor and customer expectations—the directive should support coherence. This means maintaining the risk-based scope, ensuring that SMEs receive tailored support rather than blunt carve-outs or contractual offloading, reinstating enforceable transition planning, and preserving the original liability provisions.
At the same time, meaningful stakeholder engagement must be protected, digital tools must enhance — not replace — human judgment, and assurance processes must be guided by proportionality and sector relevance. Aligning sustainability due diligence and reporting obligations, particularly between the CSDDD and CSRD, will further ease burdens and unlock synergies — especially if sector-specific guidance is prioritised.
The way forward is not deregulation, but smarter regulation: clear, coherent, and consistent. That is what will reduce costs, enhance impact, strengthen competitiveness and provide companies with the certainty they need to act.
Signatories
Suggested citation: B. Faracik, C. Marquez Carrasco, C. da Graça Pires, C. Bright, D. Schönfelder, E. von Malsen, H. Hautala, I. Schiffauer, J. Saloranta, K. Tallbo, M. Scheltema, M. Streibelt, O. Peneva, S. Swartz, S. Brabant and T. Jaekel, ‘Omnibus I – Simplification or Deregulation? A Critical Analysis and Recommendations from Practice’, NOVA BHRE Blog, 07 October 2025