Survey Shows Industry Support for CS3D

A recent survey report from WeAreEurope shows that businesses in the Euopean Union (EU) generally support the intentions of the original Corporate Sustainability Due Diligence Directive (CS3D or CSDDD) and are not happy with the uncertainty created by the proposed revisions in the Omnibus.

“Omnibus Survey 2025: Corporate Insights on the CS3D” found that while only 33% of respondents were subject to national due diligence obligations, 77% have already conducted due diligence on their value chains and activities. It also found that while proponents of the Omnibus revisions have said it is intended to ease the regulatory burden on businesses, only 19% of the respondents were dissatisfied with CS3D in its original version. Dissatisfaction with the Omnibus, however, was 63%.

Survey, Commission at Odds

According to Malte Øster, senior ESG advisor at SustainX and senior advisor at WeAreEurope, the survey refutes the narrative of the EU Commission on the necessity and support for revising the CS3D.

“The Omnibus debate has largely ignored what European companies themselves are saying,” said Øster in a communication to 3E. “Our study shows that most see value, both financial and moral, in ensuring their supply chains are free from human rights abuses and severe environmental impacts. These businesses don't view due diligence as red tape, but as good governance. While U.S. lobby groups and oil interests have pushed to weaken the law, the data tell a different story: European companies are already doing the work and want the EU to stay the course.”

WeAreEurope is a collective organization of sustainability professionals based in Europe. It advocates for sustainable business practices, economic progress, and the protection of European democracy.

A Closer Look at the Numbers

Respondents demonstrated a good understanding of the intention of CS3D, with 84% and 79% identifying preventing human rights risks and protecting the environment, respectively, as the primary objectives for the legislation. A total of 58% of respondents also identified improved supply chain transparency as an important objective. More traditional objectives, such as mitigating reputational risk (28%), complying with regulations (26%), and meeting investor expectations (21%), were found to be less important.

Respondents identified the key strengths of CS3D as the promotion of ESG accountability in supply chains (65%), advancing human rights and environmental protection (62%), and encouraging long-term risk management (61%). At the same time, they also emphasized the complexity of implementation (42%), unclear expectations and inconsistent definitions (37%), and lack of guidance (36%) as weaknesses, highlighting a persistent criticism against CS3D that large organizations are in a much better position to manage compliance than small ones that struggle with the resources to manage regulatory complexity.

Among respondents, 58% of companies reported being satisfied with the pre-Omnibus version of CS3D, and the majority reported that the Omnibus significantly (54%) or slightly (22%) weakens it. Only 6% responded that the Omnibus strengthened CS3D. In addition, companies already performing due diligence on their supply chains reported that it has already improved supply chain resilience (41%), improved ESG ratings (38%), or mitigated reputational risk (33%). A total of 30% of organizations reported that the due diligence exercise had helped them directly identify and address human rights risks in their supply chains.

Troubled Journey of CS3D

The CS3D entered into force on July 25, 2024, with the goal of encouraging sustainable and responsible supply chain practices for EU businesses and businesses operating in the EU. It creates a duty of due diligence to identify and mitigate negative impacts on human rights and the environment along the supply chain.

On February 26, 2025, the EU Commission proposed the Omnibus as a catalyst for revising key components of the Green Deal, including CS3D, the Corporate Sustainability Reporting Directive (CSRD), and the EU Taxonomy Regulation. The goal of the Omnibus was to simplify the regulatory requirements for EU businesses and to foster competitiveness in accordance with the recommendations of the Draghi Report from September 2024.

Since then, the CS3D has become a political football tossed between EU members with competing ideologies. On October 13, 2025, the European Parliament Committee on Legal Affairs (JURI) adopted its position on the Omnibus, which struck a balance between the demands of the left-leaning parties to retain the original parameters of the regulation and those of the right-leaning parties looking to get as close as possible to deregulation. Parliament proposed a scope of at least 5,000 employees and a net turnover of €1.5 billion, eliminating the civil liability scheme allowing for class-action lawsuits, and a risk-based approach to due diligence instead of restricting it to Tier 1 parties in the supply chain.

However, when Parliament voted on its position on October 22, the left-wing Socialists and Democrats (S&D) voted against it, which resulted in Parliament rejecting its own position on the Omnibus. Jörgen Warborn, lead negotiator in parliament for the European People's Party (EPP), is now likely to look to the right-wing parties, including the European Conservatives and Reformists (ECR) and the Patriots for Europe, to get the votes required for a final position, which could mean more radical reductions in regulatory requirements to satisfy those parties' demands for greater deregulation.