"Norwegian non-paper on the Commission Proposal for a Directive of the European Parliament and of the Council amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 as regards certain corporate sustainability reporting and due diligence requirements (COM/2025/81)", August 2025

In light of the ongoing work on revising the Corporate Sustainability Due Diligence Directive (CSDDD), Norway would like to share some insights from the recent evaluation of our own due diligence law and share some reflections...

The European Commission proposes several changes to the CSDDD to strengthening competitiveness and reduce regulatory burdens. The Norwegian Government would like to highlight that the CSDDD must continue to align with the UNGP and the OECD guidelines. It is important to avoid creating a new regime parallel to these international standards. We would also like to stress the importance of maintaining the principle of risk-based, proportionate and ongoing due diligence assessments. These principles are at the core of the OECD Guidelines and the UNGP and are also key elements explicitly mentioned in the Norwegian Transparency Act.

The report [commissioned by the Norwegian Government] provides an analysis of Norwegian enterprises’ experiences with the Transparency Act so far. The report shows that the Norwegian enterprises that contributed to the survey support the intentions of the Act. Furthermore, many Norwegian companies’ prioritisation of business sector human rights obligations have been significantly and systematically elevated as a result of the Act. Furthermore, several companies have also showcased examples of how the obligation to carry out due diligence assessments already has led to concrete improvements in their supply chains, for example by assessing living wage and closing wage gaps for own employees. The Transparency Act emphasises that due diligence assessments shall be risk-based...