Joint association letter on CSDDD and transition plans – September 2023
The Swiss Finance Council has co-signed a letter outlining our views on the proposed Corporate Sustainability Due Diligence Directive (CSDDD), in which we call for a more workable and proportionate approach.
We are concerned about the proposed extra-territorial scope of application, which would raise serious jurisdictional conflicts and enforcement challenges. We strongly believe that the due diligence requirements should apply only to the value chain operations related to products sold in the EU and services provided in the EU. This will not only ensure more proportionate obligations for non-EU financial institutions, but it will also improve the competitiveness of EU financial institutions operating globally and the overall attractiveness of the EU single market.
To the extent that financial institutions’ downstream value chain is included, it should be limited to the activities of large corporate clients directly receiving specific purpose loans or credits in the EU. It is crucial to ensure a harmonised approach to this within the Single Market.
We have also co-signed a letter calling for global coordination on transition plans. We believe that a consistent and interoperable approach to climate transition planning across jurisdictions is key for global financial institutions to support global decarbonisation efforts.