The Most Important Piece of Tech Regulation You’ve Never Heard Of

By: Dunstan Allison-Hope and Jason Pielemeier (Global Network Initiative)

In this article, authors Dunstan Allison-Hope and Jason Pielemeier (Global Network Initiative) examine how the Corporate Sustainability Due Diligence Directive (CS3D) applies to tech companies, including the downstream impacts arising from their operations.

Earlier this year, following considerable political maneuvering, the European Union enacted the CS3D. The result of two years of negotiation, this sweeping and ambitious law requires companies of a certain size to conduct human rights and environmental due diligence across their global operations. These obligations are reinforced through regulatory enforcement and civil liability at the EU member state level.

The CS3D builds on the Corporate Sustainability Reporting Directive (CSRD), which took effect in January 2023 and applies to large EU and non-EU companies across various sectors—though with some carve-outs for the financial industry. As a result, it affects many of the world’s leading tech companies, spanning industries from network infrastructure and personal devices to search engines and social media platforms. As a general law (lex generalis), it complements more targeted EU legislation such as the Digital Services Act (DSA), the Digital Markets Act (DMA), and the AI Act. While mirroring key aspects of these laws—such as risk assessment, transparency, and stakeholder engagement—the CS3D applies more broadly, covering a wider range of activities, geographic contexts, and businesses. Crucially, unlike these other regulations, the CS3D extends its obligations to the global operations and impacts of covered companies, with failure to comply carrying the risk of civil liability.

The post further explores how the CS3D applies to tech companies, comparing its scope to other relevant technology and corporate responsibility laws. It also examines how the regulatory framework for interpretation and enforcement is likely to develop, outlining key implications for corporate compliance…

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