In April 2024, the EU Corporate Sustainability Due Diligence Directive (EU-CSDDD) was formally adopted by the European Parliament after months of intense negotiations between Member States. The revised version amended the scope of companies affected; it now applies to: i) EU companies with more than 1,000 workers and with a global turnover surpassing €450m; and, ii) Non-EU companies generating €450m turnover in the EU.

More importantly, for companies with business activities in conflict-affected and high-risk areas (CAHRAs), the EU-CSDDD includes specific expectations related to operations, supply chains and/or value chains in conflict-affected areas (Recital 30b). In this brief, we address some of the most important questions for companies seeking to understand both the background and expectations implicit in the EU-CSDDD for their activities in CAHRAs.

This brief will address the following 8 questions:

1. What does the text say?

2. Is this policy area new?

3. Why is it necessary to have different approaches to conflict-affected and non-conflict affected areas?

4. Why aren’t human rights-based approaches sufficient?

5. What is heightened human rights due diligence?

6. Which sectors are concerned?

7. Which geographies are concerned?

8. What kind of policies does a company need to have in place for conflict-affected areas?