Less burden on CSRD requirements from Brussels

The European Commission published last February 2025 a proposal to change certain parts of the Corporate Sustainability Due Diligence Directive 2024/1760 (CS3D) to reduce the regulatory burden and potential negative economic impacts on companies. This is the Directive that establishes due diligence obligations for large companies, meaning they must identify, prevent, and bring to an end any adverse impacts on human rights and the environment that arise from their operations across the entire value chain.

Non-EU operators may be required

Most non-EU operators are not directly impacted by these obligations. However, they might be indirectly affected – they may be asked to provide specific information on the impacts their production and processing might have on human rights and the environment to help large companies demonstrate that they meet new due diligence obligations. This proposal intends to focus due diligence on any adverse impacts related to the direct business partners of large companies, and to reduce the amount of information requested from indirect business partners. It also recommends that the new requirements apply 1 year later than initially foreseen (from mid-2028).

What is changing?

The following proposed changes are likely to have implications for agri-food suppliers in low-and middle-income countries:

. Large companies operating in the EU that have to comply with the Corporate Sustainability Due Diligence Directive (CS3D) must issue a due diligence statement (assessing their own operations and measures) at least every 5 years (instead of annually).

. Large companies will only need to proactively assess potential adverse impacts in relation to direct business partners rather than all actors in the supply chain. Assessment of indirect partners will only be necessary if specific adverse impacts are identified.

. Where direct partners have fewer than 500 employees, large companies may only request information in a limited number of areas that are set out in a voluntary standard. This standard, which still has to be adopted, will be based on the Voluntary reporting standard for SMEs (VSME) published in 2024 by the European Financial Reporting Advisory Group (EFRAG).

From 2028 for larger compagnies

. Direct suppliers to large companies will have to provide contractual assurances that they will comply with the buyer’s code of conduct on due diligence. These direct partners will also have to seek contractual assurances from their own business partners (indirect business partners to the large companies) that this due diligence code of conduct is followed. Direct and indirect partners’ compliance with the code of conduct must be verified.

. The new rules will apply first to the largest companies (with more than 3,000 employees and over €900 million net turnover worldwide) from mid-2028, a delay of 1 year.

. General guidelines on how to conduct due diligence in accordance with these rules will be published by 26 July 2026, 6 months earlier than foreseen in the Directive. Source: Colead

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