By Karina Ufert, Director of External Affairs, Association of Professional Social Compliance Auditors Inc. (APSCA)
The EU’s formal adoption and publication of the Corporate Sustainability Due Diligence Directive (CSDDD), as amended through the Omnibus package, marks an important step in clarifying how companies are expected to manage human rights and environmental impacts across their chains of activities. While the final political compromise narrowed the scope and adjusted timelines, the Directive maintains a risk-based approach and confirms that companies must identify, prevent, mitigate and bring to an end adverse impacts where they are most likely and most severe. For many brands and retailers, this will mean focusing existing due diligence processes and ensuring that internal systems, supplier engagement and external assurance tools are aligned and proportionate to risk.
Article 20 of the CSDDD confirms that companies may use independent third-party verification to support their due diligence obligations — provided criteria on independence, freedom from conflicts of interest, and competence in human rights and environmental matters are met.
What this means for APSCA and social compliance auditing. For APSCA, Article 20 is a key reference point. This language closely aligns with APSCA’s role: our Code of Professional Conduct, Competency Framework and disciplinary processes are designed to strengthen the integrity, professionalism and accountability of social compliance auditors globally. When companies choose to use independent social compliance audits as part of their due diligence, APSCA conformity supports alignment with Article 20’s expectations that those audits are carried out by auditors and firms meeting recognized standards of competence, ethics and independence.
Audits as one element of a broader system. CSDDD makes clear that third-party verification forms one element of due diligence and does not replace a company’s own responsibility or potential liability. Likewise, APSCA has consistently framed social compliance audits as a structured tool within a broader due diligence plan, capable of helping to identify salient risks, inform engagement with business partners, and generate evidence to support remediation and continuous improvement for workers.
Looking ahead. As the Directive moves into the implementation and guidance phase, APSCA will continue working with member firms, member auditors, brands, investors and policymakers to clarify where audits add the most value within due diligence systems and how competent, well-governed auditing can support credible, worker-focused outcomes in practice.
This article reflects analysis from APSCA’s External Affairs function.
