"ENNHRI raises important concerns over the European Commission's Omnibus I proposal" March 2025

With this statement, ENNHRI wishes to raise concerns over the contents and the process to develop and adopt the Omnibus I proposal of the European Commission. The statement provides an analysis of the proposed changes and makes recommendations to the European Parliament and the Council of the European Union as they work towards the adoption of their mandates and in the upcoming negotiations.

In particular, ENNHRI recommends that EU institutions:

• Ensure that the next phase of the legislative process is undertaken transparently and on the basis of adequate stakeholder consultation and a solid evidence base.
• Uphold the risk-based approach to due diligence throughout companies’ chains of activities which is the cornerstone of international business and human rights standards.
• Maintain the CSDDD’s approach to responsible disengagement.
• Maintain a broad definition of stakeholders, which includes National Human Rights Institutions, and ensure that stakeholder engagement is central throughout the due diligence process.
• Maintain the original civil liability provision to ensure coherence on the conditions of civil liability across the EU and effective access to remedy for rightsholders.
• Maintain the requirement to review inclusion of the financial sector.
• Maintain the ambition of the CSRD to respond to the need for reliable and quality environmental and human rights-related disclosures, by resisting proposals to reduce the personal scope of the CSRD and allowing reporting entities to request meaningful information from other actors where necessary.
• Align the European Sustainability Reporting Standards (ESRS) with the CSDDD and international responsible business conduct standards and avoid changes to the ESRS which disproportionately reduces the social subject matter disclosures.
• Develop sector specific reporting requirements, through standards or possibly in the form of guidance.