The new Omnibus timeline indicates that companies cannot expect concrete revisions to the CSDDD and CSRD until early next year. This delay is likely to fuel anxiety and uncertainty across the corporate sphere.

Meanwhile, the impact of the Omnibus agenda is being felt across EU's suite of sustainability regulations – with the Deforestation Regulation confirmed as the next law to face the "simplification" treatment. Last week's newly published rules and Delegated Act seek to streamline corporate reporting on deforestation, in response to industry demands.

Experts warn that the Omnibus (and its ricochets across EU legislation) signals an end of the so-called "Brussels effect," which has driven a wave of HRDD regulations across the globe. It may also push the EU from its position as a world-leading standard setter to a laggard across international BHR standards.

And finally, in good news for the BHR community – the UK has passed a ban on solar panels tainted with modern slavery, setting the path for a more just transition to renewable energy.

Upcoming Events

OECD Responsible Minerals Forum: GRC Side Session on State-imposed Forced Labour

On May 7th, BHRC's sister organisation, Global Rights Compliance, is hosting a side session at the OECD Forum on Responsible Mineral Supply Chains, addressing state-imposed forced labour risks across critical mineral supply chains.

The session will provide a forum for businesses and industry actors to deepen their understanding of key mineral supply chains’ links to systemic forced labour practices – and to explore mechanisms for mitigating exposure to such harms. Register here to join us in Paris on May 7th from 3-4:30pm.

Online: Just Transition Rising Webinar

This two-day online gathering brings together union leaders, grassroots organisers, campaigners, and policy advocates to explore how justice can be placed at the heart of climate action. Register here.

Corporate Sustainability Due Diligence Directive (CSDDD)

Update:

EU Parliament will not agree on Omnibus legislation details until the end of the 2025

According to Richard Gardiner’s commentary, the EU Parliament’s timeline means there will likely be ‘no final trilogue agreement CSDDD re-writes until well into 2026.’

Gardiner writes, ‘Practically this means that even with the Stop the Clock proposal companies will have LESS time to adapt to the CSDDD (only 2 years) than if they kept the previously agreed text (which had 3 years lead-in)’

Experts have criticised the delay for causing further uncertainty for businesses, and stalling vital commitments to human rights and sustainability.

The EU Parliament's JURI Committee held its first exchange of views on the Omnibus

On LinkedIn, Heidi Hautali shared her interpretation of what this opening discussion signals for the direction of the law:

The Patriots and ECR's active opposition towards both the CSRD and CSDDD increases the chances that the EPP will compromise with S&D, Renew, Greens and the Left.

During the discussion, Hautali argued that the regulation's rapporteur had clearly listened to other MEPs and declared his willingness to negotiate in order to ”improve” the text.

8 NGOs have filed an official grievance with the European Ombudsman, criticising the way the Omnibus process was crafted and executed by the European Commission (EC).

The coalition of NGOs, which includes Anti-Slavery international, Client Earth and Global Witness, argues that the Omnibus process was ‘undemocratic…expedited’, and opaque.

In a joint statement, the groups said: ‘We are contesting the commission’s rushed dismantling of three key pillars of the Green Deal – including laws meant to improve the environmental and human impacts of global trade – a process that completely disregards people and nature’s rights.’

Notes/Further Reading:

Despite the US’ recent backlash against ESG principles, new reporting by Reuters provides strong evidence that U.S. companies are maintaining, and even planning to expand, their sustainability commitments.

Reuter's White Paper "The State of Sustainability Reporting by U.S. Business in 2025", recounts interviews with leading representatives of eight major U.S. companies, including Microsoft and PayPal.

U.S. companies are shown to be upholding '96 per cent of existing sustainability targets, whilst nine-in-ten of investors are maintaining their environmental, social and governance (ESG) investments.'

Richard Gardiner’s think piece in Green Central Banking: Ripples from EU omnibus threaten to disrupt global sustainability standards

The article shares insights into how the EU has accelerated sustainability business activity across the globe – and warns against how the Omnibus may stall the momentum of this global movement.

The piece stresses the importance of the EU in maintaining global standards and not dipping below as a result of simplification. In his words, international standards bring 'greater predictability and legal certainty to responsible business expectations and for both companies and investors.'

Implementation timeline:

  • 31 December 2025: Member states must transpose 'stop the clock' directive into their national legislation.
  • From 2028 [delayed]: Companies with 5,000+ employees and a net turnover of 1 ,500 million EUR must comply.
  • From 2028 [unchanged]: Companies with 3,000+ employees and a net turnover of 900 million EUR must comply.
  • From 2029 [unchanged]: Companies with 1,000+ employees and a net turnover of 450 million EUR must comply.

EU Deforestation Regulation (EUDR)

Updates:

The EU relaxes deforestation law reporting for companies.

On April 15th, the EU Commission published updated guidance on the EUDR, [available here], seeking to streamline the regulation.

Most notably, under the new rules companies will only have to submit an annual due diligence statement, rather than reporting on each shipment or batch of goods placed on the EU market.

The guidance also simplifies measures by allowing ‘authorized representatives to submit due diligence statements on behalf of members of company groups’ and that ‘large companies will be able to reuse due diligence statements when goods previously on the EU market are reimported.

The move appears to respond to industry demands for a reduction in administrative burdens.

The EU Commission published a draft delegated act for public consultation, aiming to further simplify the scope of the EUDR.

The delegated act, also pulished on April 15th, proposes to ‘Annex I of the Regulation (EU) 2023/1115 … to introduce targeted and limited technical fixes to the list of relevant products, by clarifying the range of products not covered by the Regulation’.

The Commission claims the revisions are ‘necessary to ensure a simpler and more straightforward application of the EUDR and legal certainty.’

The consultation is open until May 13th.

Further Reading/Listening:

NYT investigation into the scramble for Ethiopian coffee farmers to meet the EUDR requirements

Interviewed farmers say they need more time to ensure compliance with the regulation.

New EU Commission Frequently Asked Questions on the EUDR, published on April 15th.

Implementation timeline:

30 June 2025: Country benchmarking act adopted. Obligations stemming from the regulation will be binding from:

  • 30 December 2025: for large operators and traders
  • 30 June 2026: for micro- and small enterprises

EU Forced Labour Regulation (EUFLR)

Update: None

Further Reading:

Human Rights Watch and the Cornell Global Labor Institute (GLI)'s Q&A on the EUFLR.

The explainer answers questions on the application and enforcement of the law, including how investigations will be conducted and the possibility of removing sanctions on products.

Implementation timeline:

  • 2026: EU Commission to publish guidelines, including a forced labour risk database.
  • 14 December 2027: law becomes applicable.

Uyghur Forced Labor Prevention Act (UFLPA)

Updates: None

Further Reading/ Listening:

The UK has passed a ban on solar panels linked to forced labour.

The amendment to the Great British Energy Bill forces companies to ensure that there is no slavery or human trafficking in its supply chain.

The legislation seeks to protect the UK market from exposure to Uyghur forced labour – given that between 35% and 40% of polysilicon, the key raw material for solar panels, is produced in the XUAR.

Sourcing Journal Op-Ed: Is the US still in the fight against forced labour?

Disclaimer: This newsletter is for general informational purposes only. It does not, and is not intended to, constitute legal advice.