Last month the Danish Institute for Human Rights published four briefing papers to help non-EU stakeholders, including businesses, civil society organisations, trade unions and policymakers, understand and engage with the EU’s Corporate Sustainability Due Diligence Directive (CSDDD). The briefs are a valuable resource: they break down the directive’s core elements, explain what it means in practice for organisations outside the EU, and outline opportunities for engagement. They arrive at a significant moment, with the Omnibus I amendments now legally in force as of March 2026, and obligations applying to large companies from 2029.
But understanding what the directive requires is only half the story. To assess what it can deliver, we also need to examine how it got here and how corporate lobbying shaped it.
A directive under siege from the start
The CSDDD had a turbulent passage from its original proposal in 2022 to its current form. What began as an ambitious framework to hold companies accountable for human rights and environmental harms across their global value chains has emerged significantly weakened, the result of years of intense negotiation and sustained corporate lobbying pressure.
Our own research at Social LobbyMap documented the scale of this lobbying campaign. A report published in June 2025 analysed how 88 companies and industry bodies engaged with the CSDDD in the four years leading up to its initial passage, including 10 energy companies — though the total number of entities lobbying the directive during this period was considerably higher. Of the thematic areas covered by the directive, corporations lobbied most aggressively against the general requirement for human rights due diligence and against full value chain coverage. The financial sector and cross-sectoral trade associations led the opposition, with the finance sector successfully securing the exclusion of downstream lending and investment activities from the directive’s scope entirely.
The lobbying didn’t stop there. When the European Commission launched its Omnibus I simplification package in early 2025, only months after the CSDDD was first adopted, many of the same actors seized a second opportunity to influence the directive, and the process by which the Omnibus was developed raised serious transparency concerns in its own right.
To shape the proposal, the Commission held two stakeholder roundtables in February 2025, both of which were closed, invite-only, and not made public at the time. Their purpose and participant lists only came to light after the agenda was leaked to the media, as ActionAid’s legal letter on the consultation process documented at the time. Of the 68 entities invited to participate, only ten came from civil society, while large corporations accounted for 58 invitations, some of which were at the time subject to legal proceedings for human rights violations. The result was a consultation process that structurally amplified corporate concerns while civil society voices were largely excluded. The gravity of this was subsequently confirmed by the European Ombudsman, who in November 2025 found that the Commission had committed maladministration by failing to consult all relevant stakeholders and bypassing the impact assessment and climate consistency assessment required under its own Better Regulation rules.
Those corporate concerns about harmonisation, complexity and regulatory burden dominated the roundtable outputs. Specific sectors, including finance and energy, pushed for narrower value chain scope and reduced reporting obligations, and those preferences were then closely reflected in the Omnibus proposal that followed. Beyond the roundtables, our Omnibus research found that MEPs logged 631 meetings on the Omnibus from December 2024 onwards, the overwhelming majority with trade associations and large corporations. ExxonMobil and TotalEnergies alone logged eight and ten MEP meetings respectively on the topic.
The asks and what was granted
The Omnibus phase is particularly instructive because it allows us to map specific lobbying demands against specific legislative outcomes. Our Omnibus report examined corporate and trade association positions across the proposal’s main areas of contention, and comparing those positions with the final adopted text reveals a significant pattern of success for those pushing for rollback.
Scope reduction was among the most intensely lobbied asks. Trade associations argued that the original thresholds, covering companies with over 1,000 employees and €450 million in turnover, were too broad. The final Omnibus I text raised those thresholds to 5,000 employees and €1.5 billion in turnover, cutting the number of companies in scope from tens of thousands to approximately 1,600.
Civil liability was consistently the most polarising issue across both rounds of Social LobbyMap research, with entities either strongly supportive or strongly opposed. It is worth explaining what was at stake: the CSDDD originally contained two distinct enforcement tracks. The first is administrative enforcement, whereby national supervisory authorities can investigate companies, impose fines of up to 5% of global turnover, and order compliance — a form of public enforcement by the state. The second, civil liability, is a separate private mechanism that would have allowed affected individuals, communities, trade unions and NGOs to sue companies directly in court and seek damages when due diligence obligations were breached. Opponents lobbied heavily against both, arguing that mandatory EU-wide provisions would expose companies to unmanageable legal risk. The Omnibus text scrapped the harmonised civil liability regime entirely — removing victims’ ability to seek damages through a standardised EU-wide route — while the administrative enforcement track, including supervisory authorities and financial penalties, was retained.
Value chain scope was the second most lobbied thematic area in our research. Opponents pushed to restrict due diligence obligations to a company’s direct, Tier 1, suppliers rather than requiring assessment across the full value chain, and the Omnibus proposal initially reflected this ask. However, strong advocacy efforts were successful in preventing this from becoming law: the final text preserved a risk-based approach across a company’s broader chain of activities, rejecting the proposed Tier 1-only restriction.
Climate transition plans disappeared from the directive altogether, a change directly linked to pressure from European industry voices and compounded by the political environment created by the US administration’s own rollback of ESG-related regulation. The obligation to terminate business relationships where harms cannot be prevented or mitigated was also significantly weakened, despite our research finding that it was a provision many entities had actively lobbied to remove.
Taken together, the adoption of the Omnibus Simplification package delivered a set of changes that closely mirrors what the most active opponents had sought, through a process that was itself structured in ways that favoured corporate voices.
The say-do gap in action
A recurring theme in our research is what is commonly referred to as the “say-do gap”: the observable divergence between the positions companies take publicly on legislation and the lobbying activity carried out on their behalf, often through trade associations. Social LobbyMap’s methodology tracks lobbying positions, what companies and their associations say in consultation responses and policy engagements, rather than auditing companies’ broader sustainability commitments. Within that scope, a clear pattern emerged.
Individual companies were generally more supportive of the CSDDD than their trade associations, but trade associations lobbied with greater intensity, resulting in oppositional voices being amplified while more supportive voices were drowned out. Some companies, including Nestlé, Unilever and L’Oréal, publicly distanced themselves from their trade associations’ positions on specific provisions. Others were members of associations whose lobbying positions were markedly more opposed to the directive than the companies’ own stated views.
This misalignment matters beyond transparency. When the loudest and most coordinated voices in a legislative process are trade associations whose positions do not reflect those of their own members, and when the consultation processes designed to gather stakeholder input are structured to overrepresent those same actors, the policy outcomes become distorted. The CSDDD’s Omnibus revisions reflect, in part, this exact dynamic.
Reading the Danish Institute briefs with this in mind
The Danish Institute’s briefs are designed to help stakeholders outside the EU understand and engage with the CSDDD as it now stands, and that is valuable and necessary work. The directive, even in its revised form, creates real obligations and real opportunities for engagement, and the briefs do an excellent job of making those accessible to a wide audience.
Stakeholders will engage with it more effectively, however, if they understand that the current text is not the version originally proposed. The scope is narrower, the liability provisions are weaker and the value chain requirements are more limited. Each of those changes has both a lobbying history and a process history that our research has sought to document and make visible. That pattern has not ended with the Omnibus: a major new report published in April 2026 by Corporate Europe Observatory found that corporate lobby groups continue to dominate the Commission’s broader simplification agenda, with business representatives accounting for 84% of Omnibus-related Commissioner meetings in 2025 — suggesting that the pipeline from lobbying to lawmaking identified in our own research remains very much active.
What comes next
The Omnibus I amendments entered into force on 18 March 2026, and EU Member States now have until July 2028 to transpose the revised directive into national law. Two upcoming Commission milestones are particularly worth watching: the publication of CSDDD implementation guidelines, due by July 2027, which will provide more concrete guidance on how companies are expected to operationalise their due diligence obligations; and the development of revised European Sustainability Reporting Standards for CSRD, expected in Q2 2026. Both processes are likely to attract significant lobbying activity and will shape how the directive functions in practice.
The transposition phase itself will bring a new wave of corporate political engagement that is important to monitor, given that national legislative processes typically attract far less scrutiny than EU-level negotiations. The same companies and industry bodies that shaped the Omnibus outcome are likely to engage actively with national lawmakers, and the constraints of the full harmonisation provisions mean that the space available for Member States to strengthen the directive’s protections, while still meaningful in some areas, is more limited than it might appear.
For the civil society groups, trade unions and policymakers that the Danish Institute’s briefs are designed to support, understanding the lobbying forces that have shaped the CSDDD is not merely background context. It is essential to knowing what the directive can realistically deliver, and what still needs to be advocated for.