The Omnibus is moving quickly through the EU Council and Parliament – with a focus on passing the "Stop the Clock" proposal, which would postpone the CSDDD and CSRD reporting requirements by at least a year.

MEPs will vote on this delay on April 1st, with a secondary vote expected over the following days if it's passed. Meanwhile, the EU Council has already accepted this proposal, as part of its broader commitment to uphold (and in some cases advance) the Omnibus initiative's simplification agenda.

This edition of the Debrief also features news from the UK – as part of our new spotlight feature – to mark the 10th anniversary of the Modern Slavery Act, and unpack the defeat of a landmark amendment to stop the purchase of solar panels tainted by forced labour.

Keep reading to find out more...

Upcoming BHR Webinar

Our next webinar will address the challenges of working in occupied territories, including in the OPT and Western Sahara. Working in occupied territories presents unique challenges for business in respecting the human rights of those communities that remain in those territories. This seminar will explore some of the complexities of assessing what is responsible business and whether and how it is possible to avoid contributing to war crimes (e.g., forcible displacement, unlawful use of public and private property, etc.,), or violating fundamental principles of international law, including the unlawful use of force, the right to self-determination, non-discrimination, etc.).

Register here to join us on April the 3rd at 1pm CET.

Corporate Sustainability Due Diligence Directive (CSDDD)

Updates:

The EU Council confirmed high-level support for the Omnibus initiative and accepted the “stop the clock” proposal.

The Council expressed support for the Omnibus and called for co-legislators to expedite action on the initiative. These conclusions, which were adopted, also called on the EU Commission to ‘further simplify’ the regulations.

The following week, the European Council confirmed its support for delaying the CSRD and CSDDD reporting obligations, under the “stop the clock” proposal.

This decision means the Council can will enter into ‘interinstitutional negotiations’ with the EU Parliament on the stop-the-clock proposal.

EU Parliament vote scheduled on the “stop the clock” fast track proposal.

The Parliament has scheduled an April 1 vote on the 'Rule 170 Urgent Procedure' request to fast-track the proposal seeking to delay transposition and implementation of the laws.

Investors take fire at the Omnibus’s “deregulatory” amendments to the CSRD and the CSDDD

Asset managers and investors claim that the Omnibus proposal may restrict them from adequately assessing their portfolios by limiting available information and data.

In the ‘Sustainability Omnibus Podcast’ Tessa Younger, stewardship lead at investment and asset management firm CCLA, explains how the Omnibus proposal’s weakening of standards would impact companies and investors operating beyond its jurisdiction.

Meanwhile, the Head of Research at the European Capital Markets Institute (ECMI) penned at op-ed for IPE, entitled, ‘EU omnibus is a sustainability retreat, not a simplification.’

Notes/ Further Reading:

Thailand to introduce a social and environmental due diligence law

At a moment when it appears as if efforts to enforce robust due diligence are backsliding, Thailand is bucking the trend by introducing a new progressive human rights and environment due diligence law.

Keri Lloyd unpacks key takeaways from vent co-hosted by MEP Axel Voss and the Responsible Business Alliance, including a renewed focus on ‘centering risk-based due diligence.’

Implementation timeline:

  • 1st April 2025: EU Parliament vote expected on the “stop the clock” proposal (part of the omnibus simplification package.)

[Following timeline is now subject to change in response to the Omnibus]

  • Present - 26 July 2026: Member States transpose the requirements set by the Directive.
  • 2026/2027: CSDDD takes effect at the national level.
  • From 2027: Companies with 5,000+ employees and a net turnover of 1 ,500 million EUR must comply.
  • From 2028: Companies with 3,000+ employees and a net turnover of 900 million EUR must comply.
  • From 2029: Companies with 1,000+ employees and a net turnover of 450 million EUR must comply.

EU Deforestation Regulation (EUDR)

Updates:

A Zoological Society of London (ZSL) assessment finds that only one of the world’s top twelve tire manufacturers were willing to provide evidence that there supply chains were deforestation-free.

The report assessed rubber companies and tire manufactures to determine what portion of their supply chain is independently verified as deforestation- and conversion-free (DCF).

Of the 12 tire companies analysed, only the French giant, Michelin, used a third-party to independently evaluate 9% of its supply chain.

Further Reading/ Listening:

FT Adviser piece on: Why should I care about deforestation as a retail investor?

The op-ed breaks down the human, ecological, health and economic consequences of deforestation.

Implementation timeline:

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: None

Implementation timeline:

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

Feature: 'Forced to Work by the State' Explainer

Last week, BHRC's sister organisation, Global Rights Compliance, published 'Forced to Work', a legal and practical analysis of how state imposed forced labour (SIFL) manifests globally. The publication breaks why SIFL stands apart from other form of forced labour, and why it demands urgent attention from businesses - not just as a human rights imperative, but as a growing corporate risk in an increasingly regulated world.

Read the full explainer here.

 

Uyghur Forced Labor Prevention Act (UFLPA)

Update: None

Recommended reading:

Reuters delves into isotopic testing, the groundbreaking technology that is improving supply chain resilience and verifying compliance with the UFLPA.

Isotopic testing looks at the unique atomic composition of goods, which acts as a distinctive fingerprintand is influenced by the local environment in which the material originated. The tech provides enforcement agencies with a unique tool to verify that companies are complying with modern slavery laws.

Spotlight: UK Modern Slavery Laws Make Headlines

The UK government rejected an amendment which would ban solar panels exposed to forced labour abuses.

MPs in the UK whipped to reject the amendment to the Great British Energy Bill, which would have banned the UK from procuring solar panels tainted by forced labour in China.

The government’s rejection of the bill has been criticised by many for greenwashing severe human rights violations.

The government claims it was the wrong vehicle for modern slavery action. As consolation, Michael Shanks, the energy security minister, said the government would strengthen its efforts to tackle forced labour including appointing a “a senior individual” in GB Energy to lead on ethical supply chains including modern slavery, and that the company’s strategic priorities would include working proactively to tackle it.

The UK marks the 10-year anniversary of the Modern Slavery Act

The UK human rights community is reflecting on progress (and lack thereof) made since the passage of the landmark law in 2025.

In an article, the International Bar Association note that international best practice has moved on significantly over the past 10 years, exposing cracks in the UK's legislative framework. Lara Strangways, Head of Advisory at BHRC, comments that without introducing financial penalties or criminal liability for businesses who fail to comply with modern slavery legislation, ‘we risk the UK becoming a dumping ground for forced labour products.’

To commemorate the anniversary, human rights and anti-slavery campaigners from Stop Uyghur Genocide and Anti-Slavery International delivered a petition to Downing Street calling for import controls, with over 10,000 signatures.

Finally, last week, the UK Home Office published updated statutory guidance to Transparency in Supply Chains Section 54 of the Modern Slavery Act 2015.

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