SLCP calls for simplification without compromising meaningful HRDD in new Omnibus position paper
On 26 February 2025, the European Commission published the Omnibus Simplification Package I - Simplifying EU rules and boosting competitiveness. The proposal aims to make sustainability reporting more accessible and efficient and simplify due diligence requirements to support responsible business practices, among other objectives. The text introduces significant amendments to the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD), including narrowed due diligence obligations and a delayed implementation.
Last week, SLCP signed a joint statement urging EU policymakers to consider adapting the Omnibus proposal for better risk management and worker and environmental protection.
Today, SLCP is sharing our own positioning, reaffirming that simplification of compliance requirements should not just be about efficiency. Rather, it should be about keeping legislation in line with original objectives, and avoiding implementation delays.
While SLCP’s mission and vision remains relevant to the current Omnibus proposal – as the Converged Assessment Framework (CAF) aims primarily to reduce audit duplication and create efficiencies – some of the changes in the Omnibus proposal are deeply concerning to SLCP, and risk leading to further market fragmentation and ongoing legal uncertainty for supply chain actors.
SLCP calls on the following points in the Omnibus proposal to be revisited by EU policymakers:
Need for risk-based due diligence
Call for a level playing field by including indirect business partners
Consistency on the scope of direct business partners
Clarity on what qualifies as ‘plausible evidence’
Need for sector specific standards and guidance as highlighted in the Handbook for Due Diligence Implementation in the Textiles sector.
Significant reduction in monitoring expectations increasing likelihood of ineffective due diligence efforts
Aligning limits to SME information requests with existing verified broad social assessment tools
Promotion of companies going beyond minimum compliance, creating a race to the top rather than a box-ticking exercise.
The European Parliament and EU Council must ensure that simplification does not compromise the positive impact the original CSDDD and CSRD would have had on workers in the supply chain. It is crucial to keep in mind the investment the industry has already made towards compliance with existing frameworks.
SLCP has conducted comprehensive tool alignment activities to ensure that the CAF is aligned with the CSDDD and CSRD. These alignment activities will continue, with a focus on further integrating Human Rights Due Diligence (HRDD) frameworks, which are consistent with these Directives, as well as OECD Guidelines and the UN Guiding Principles on Business and Human Rights (UNGPs).
