EBF Position paper – Corporate Sustainability Due Diligence Directive (CSDD)

EBF Position paper – Corporate Sustainability Due Diligence Directive (CSDD)

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Brussels, 20 June 2022 – The EBF position on Corporate Sustainability Due Diligence Proposal

Key issues

• The directive should clarify whether it is asking financial entities to identify the adverse impact just once during the onboarding of the client or for each new product/service contract a company is selling to a same client.
• The EBF position is that the obligations of this Directive should apply at the consolidated group level and subsidiaries should be expressly exempted.
• The notion of “directors” should be clarified. The proposal does not seem to distinguish between executive and non-executive directors, or even between members of the board of directors or senior managers.
• We strongly oppose the inclusion of the proposed provisions on civil liability (article 22) and the payment of damages to affected groups (article 8) in the Directive. They go against the established principles of national civil law and create an unaccountable and uncertain legal risk for companies.

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For more information:

Denisa Avermaete, Senior Policy Adviser, Financing Sustainable Growth, d.avermaete@ebf.eu

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About the EBF:

The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.