Earlier this week, the Society submitted this updated position paper to numerous members of the European Parliament, Commission, and Council in advance of the European Parliament’s June 27 internal deadline to submit its proposed amendments on the European Commission’s Omnibus Simplification Proposal.
The updated position paper refines the positions the Society articulated in its initial position paper submitted to various EU officials in February 2025 (before the Omnibus Proposal was released) across three discrete areas encompassed within the Omnibus Proposal: I. Revisions to European Sustainability Reporting Standards (ESRS); II. Extraterritorial Implications of the Corporate Sustainability Reporting Directive (CSRD); and III. Necessary amendments to the Corporate Sustainability Due Diligence Directive (CS3D).
The Society is hugely appreciative of the expertise, collaboration, and extraordinary efforts over the past ~10 weeks of the following drafters and contributors: Seth Engel (Jones Day), Betty Huber (Latham), Jennie Morawetz (Kirkland & Ellis), Julie Rizzo (K&L Gates), and Marc Rotter (Ropes & Gray), as well as the in-house members of the position paper working group, and Freshfields for their guidance and support throughout the process.
The submission follows on the heels of the Society’s robust response in May to EFRAG’s public consultation on revisions to the ESRS and our signing onto a joint AmCham EU-led “stop the clock” statement in March, which was adopted by the European Parliament and Council in April.