The European Commission is working on guidelines designed to help companies implement the CSDDD in practice. The obligation to develop these guidelines stems from Article 19 of the directive: the first part of the guidelines is to be made available by July 26, 2027, and the remainder by July 26, 2028. The public consultation, during which the Commission gathered input from companies, organizations, and practitioners, was open until August 14, 2026.
The questionnaire consisted of 57 questions grouped into a dozen or so thematic blocks and assigned to specific stakeholder groups. The Commission asked, among other things, about the integration of due diligence into policies and risk management systems, the identification of adverse impacts along the value chain, risk factors and data sources, digital tools, prioritization, procurement practices, wages and income ensuring a decent standard of living, support for SMEs, remedial measures, conflict-affected and high-risk areas, information sharing among partners, model contractual clauses, industry and multi-stakeholder initiatives, third-party verification, and stakeholder engagement.
We answered 44 out of 57 questions. Our position is based on our day-to-day consulting practice: we work with both companies that send inquiries as part of their due diligence and those that receive them and must respond. This dual perspective shapes the way we have answered questions about the costs, proportionality, and practical feasibility of specific solutions.
The published document contains the full text of the response sent to the Commission, in English along with a translation into Polish. We have supplemented it with additional details that could not be included in the questionnaire due to character limits, and we have clearly marked them as material not submitted.
We invite you to read this article. If you would like to discuss any of the topics covered in the context of your own organization or supply chain, We are at your service.