Brussels, 5 February 2025
Dear President Ursula von der Leyen,
Dear Executive Vice-President Stéphane Séjourné,
Dear Commissioner Valdis Dombrovskis,
Please consider this statement as joint input to the European Commission Roundtable Consultations on "Simplification" due to take place on 5 and 6 February.
We are representing a broad range of stakeholders who have worked for decades in the protection of human rights and the environment, and are now focused on the intended application of key European Union sustainability legislations.
We are deeply concerned by the current direction of policy-making within the European Commission, particularly regarding the introduction of measures that can potentially weaken or undermine previously agreed legislation crucial to the EU’s sustainability goals.
In particular, we wish to state unequivocally that we firmly oppose any re-opening of previously agreed legislation, such as the Corporate Sustainability Due Diligence Directive, at level one. We believe that such a move would risk creating regulatory uncertainty, jeopardising investments already made and necessary future investments, undermining rights of citizens who have been affected by companies’ operations, delaying progress, penalising companies that have already invested significantly in compliance, and eroding the trailblazing EU leadership on corporate sustainability standards.
We reaffirm our strong support for focusing on the effective application of the laws through further interpretative measures and guidance, as was foreseen and agreed. We understand that both business and stakeholders need further clarifications on the key provisions of the rules, and we remain committed to working on these both through the planned implementing stages and expected guidance, including with national supervisors, governments and international platforms.
We also take this opportunity to publicly express our concern regarding the way the "consultations" for this potentially very harmful decision-making process are being conducted. While we note that the Commission has committed to act quickly, we consider that the current approach is not in line with the European Commission’s own Better Regulation framework. The current approach, marked by the lack of a thorough impact assessment, absence of evidence, disregard of previous political consensus, and limited transparency and inadequate and business-biased stakeholder inclusion is simply inadequate in view of the nature and potentially far-reaching scope of this Omnibus initiative. This threatens to erode trust in the EU’s legislative process and undermine the legitimacy of crucial sustainability measures at a time when inclusive governance is most needed.
Therefore, we reiterate our firm request that the European Commission does not create further confusion and uncertainty through re-opening agreed legislative texts, but instead focuses on practical application through an inclusive and transparent process.
We would also refer you to the multiple other statements recently published which we urge that you take these into consideration.
– Major businesses urge Commission to ensure ’Omnibus’ approach will not allow renegotiation of agreed texts, incl. CSDDD
– European NHRIs raise concerns in relation to the European Commission’s Omnibus proposal.
– Joint statement by over 170 members of civil society, human rights and environmental defenders, trade unions and climate activists on how omnibus proposal will create costly confusion and lower protection for people and the planet.
– Over 150 Business & Human Rights experts from legal practice, business, consulting and academia voice grave concerns regarding ’Omnibus’ proposal.
– Multi-stakeholder statement "Smart implementation of EU sustainability reporting standards: make complying with rules easy"
– Open letter to the European Commission: 230 researchers, mainly economists, warn against the Omnibus proposal.
– Investors warn Omnibus package could weaken EU sustainability disclosures, harming investment and economic competitiveness.
– 400 Chief Sustainability Officers in French Companies ask EU not to water down ESG rules.
See the full list of signatories here.
See also a legal letter addressed to the European Commission on 4 February 2025, co-signed by FIDH and available here.