On 13 August 2026, Due Diligence Design submitted its response to the European Commission’s public consultation on the forthcoming Guidelines for the Corporate Sustainability Due Diligence Directive (CSDDD).
Our submission focused on how the Guidelines can support companies to implement effective, risk-based due diligence in practice, particularly in relation to risk identification and prioritisation, digital tools and stakeholder engagement.
Key points raised include:
- Effective risk scoping requires more than a single dataset or rating. It should combine reasonably available information on inherent country, sector and value-chain risks with credible external reporting and stakeholder evidence, followed by a consistent methodology for assessing severity and likelihood.
- Digital risk-scoping tools are most useful where they integrate multiple evidence types across geographies, sectors and value-chain stages; retain source-level traceability; and update as risk contexts change. They are most valuable when they do not simply aggregate data, but integrate evidence into a transparent analysis, informed by expert judgement, that can account for qualitative, incomplete or conflicting information.
- Digital tools can create false precision where underlying evidence is weak. Key difficulties include opaque or non-traceable ratings, inconsistent coverage across countries and value-chain stages, excessive volumes of data without prioritisation, and reliance on information collected only from known suppliers.
- Prioritisation should remain anchored in the severity and likelihood of adverse impacts, rather than commercial exposure or ease of action. It should also be dynamic, with material changes in operating context, stakeholder evidence or emerging reports triggering reassessment.
- Absence of reported incidents should not be treated as evidence of low risk. Audit and incident data are limited to risks that have been detected or reported and may provide a poor basis for assessing hidden or systemic harms; inherent risk information is also needed.
- Meaningful stakeholder engagement should strengthen risk identification and interpretation, particularly where evidence is limited, risks are under-reported or contexts change rapidly. Companies should prioritise representative organisations, particularly trade unions, while ensuring that marginalised or less visible stakeholders’ experiences are captured without requiring direct engagement with every affected individual or group.