"IHRB response to European Commission Consultation on Corporate Sustainability Due Diligence Directive (CSDDD) guidance", 4 August 2026

IHRB has submitted its response to the European Commission's open public consultation on guidelines for implementing the Corporate Sustainability Due Diligence Directive (CSDDD).

After the Omnibus revisions, much of the detail that will determine whether the CSDDD works in practice now sits with the guidance the Commission is preparing, which will cover due diligence process, purchasing practices, model contract clauses, industry initiatives, third-party verification, stakeholder engagement and more. 

IHRB’s response centres on the premise that the guidelines should keep the Directive firmly anchored to the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines, and help companies focus on risks to people, not only risks to the business.

Our response draws on IHRB's practical work, from the Employer Pays Principle and the Leadership Group for Responsible Recruitment, to the Myanmar Centre for Responsible Business (MCRB) and our programmes on migrant workers and the built environment. Across 56 questions, a few themes recur:

Meaningful stakeholder engagement...

Reaching workers most at risk...

Purchasing practices and fair prices...

Conflict-affected and high-risk areas...

Collective action needs support to work...

We also encourage the Commission to convene and support this work in-country rather than only at headquarters, to guide Member State embassies on CSDDD implementation, and to bring reliable guidance and data together in a single accessible portal, building on the model of the EU Forced Labour Portal