Addressing extraterritoriality in the EU’s sustainability framework
Position Paper
4 Nov 2025
Corporate sustainability, simplification

Joining other third-country business groups, AmCham EU has co-signed a joint statement outlining concerns about the extraterritorial implications of the Corporate Sustainability Due Diligence Directive (CS3D) and the Corporate Sustainability Reporting Directive (CSRD). The letter highlights concerns regarding legal uncertainty created by certain extraterritoriality requirements in the ongoing Omnibus 1 process and outlines recommendations to ensure a clear, workable framework for all companies operating in or engaging with the EU market.

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Simplification is moving. But EU policy still hasn’t seen the complete mindset shift it needs.

Authored by Malte Lohan, CEO, AmCham EU

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