Updated – Alignment within Reach: Remaining opportunities to align the EU CSDDD with the OECD Guidelines

Recommendations for EU policymakers and member states to correct lack of alignment between EU CSDDD and the OECD Guidelines

In 2024, the European Union adopted the landmark Corporate Sustainability Due Diligence Directive (CSDDD), introducing the first EU-wide legal requirement for large companies to identify and address human rights and environmental harms in their operations and value chains.

However, in 2025 the Directive was amended through the Omnibus Simplification Package. These changes raised questions about how closely the revised Directive still aligns with leading international responsible business conduct standards, particularly the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines).

This paper examines the alignment between the amended CSDDD and the OECD Guidelines, building on OECD Watch’s earlier analysis of the original Directive, which you can see here. It finds that while the CSDDD remains an important step toward translating international standards into binding law, the Omnibus amendments have in several areas weakened alignment with the OECD Guidelines. The Directive applies to a smaller group of companies, the value chain scope remains incomplete, the material scope of human rights and environmental impacts is narrower than that found in the OECD Guidelines, and important gaps remain in the six-step due diligence framework.

Despite these shortcomings, the paper highlights several opportunities to strengthen alignment between the Directive and the OECD Guidelines in the coming years:

• EU Member States can clarify and strengthen certain provisions during the national transposition process.
• The EU Commission’s implementation guidance for companies and regulators can draw more directly on OECD due diligence standards.
• The Directive’s scheduled review in 2031 provides an opportunity to close remaining gaps.

This paper can support policymakers, civil society, and other stakeholders in ensuring that EU due diligence legislation fully aligns with the OECD Guidelines.