At EIRIS Foundation, we support the call on EU policymakers to preserve CSDDD Omnibus review clause
We are proud to stand with 31 other organisations as a signatory to the joint letter coordinated by ShareAction, calling on the EU to preserve the “review clause” in the Corporate Sustainability Due Diligence Directive (CSDDD) — a critical mechanism that keeps alive the possibility of extending mandatory human-rights and environmental due diligence to financial undertakings.
This aligns closely with our Social LobbyMap work. In November 2024, we published our in-depth report: Financial Sector Lobbying of the EU Corporate Sustainability Due Diligence Directive: a Social LobbyMap Analysis. It outlined how financial-sector actors and trade associations influenced the negotiations to exclude downstream investment and lending from CSDDD’s scope. Key findings included:
· The EU Council’s central role in pushing the carve-out
· Strong opposition from certain member-states (notably France, Spain, Italy, Bulgaria, Slovakia) facilitating this outcome
· A disconnect between companies and the positions adopted by trade associations
· A transparency deficit in lobbying around human-rights policy
Crucially, our report explains how the “review clause” in Article 36(1) — which was preserved in the version of CSDDD that became law in 2024 thanks to concerted advocacy — offered a second chance to address this exclusion by July 26, 2026, when the Commission was to evaluate the need for further legislative requirements for regulated financial actors.
We encourage asset managers to see CSDDD as a risk management tool. By aligning the expectations of assets managers with what is expected of companies, the EU can reassure long-term asset owners and retail investors that sustainability risks will be effectively managed as they allocate capital to innovation and transition.
We call on policymakers, investors, civil society and financial institutions to mobilise now — to preserve the review clause as an opportunity to align legislation with global standards on human rights and climate accountability.
Read ShareAction’s joint letter here:
Download our full report here: https://lnkd.in/e_43HyRX
At EIRIS Foundation, our mission is to drive transparent, accountable and socially responsible corporate and investment practices. The Social LobbyMap is one of our flagship tools — spotlighting where corporate political engagement undermines human-rights and sustainability ambitions and where positive change can emerge.
Together, we must ensure that financial flows do not escape responsibility, and that future legislative reviews close these gaps — for people, planet, and accountability.