European Commission Consultation on Corporate Sustainability Due Diligence Directive Implementation Guidelines

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank (Norges Bank), responsible for investing the Norwegian Government Pension Fund Global on behalf of the Norwegian people. We are a globally diversified, long-term investor across more than 7,200 companies in 65 countries. As of year-end 2025, we managed EUR 1.79 trillion in assets, including EUR 232 billion invested across 1,080 companies in the EU Member States. We welcome the opportunity to respond to this consultation on guidelines to support the effective implementation of the Corporate Sustainability Due Diligence Directive (CSDDD, Directive 2024/1760).[1]

As a long-term investor, we depend on reliable and comparable sustainability information to make informed investment decisions, assess material risks, and engage effectively with companies through stewardship. The approach these forthcoming CSDDD implementation guidelines take to due diligence processes, risk prioritisation and stakeholder engagement will speak directly to our interests in European companies and their value chains.

Our expectations of investee companies, and our own approach to sustainability due diligence as an investor, are based on internationally recognised standards for responsible business conduct, in particular the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises.[2] We would therefore encourage the European Commission to ensure these guidelines are closely aligned with these standards, including the concepts of causing, contributing to, or being directly linked to an adverse impact. This would keep the framework coherent with the global standards for responsible business conduct that companies and investors increasingly apply.

We set out our responses to the most relevant consultation questions in the appendix below, and appreciate the Commission's consideration of our perspective. We remain available for further discussion.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer

Dr Shilpi Nanda
Senior Policy Advisor

[1] Corporate sustainability due diligence – development of guidelines.

[2] NBIM, Human rights - Expectations of companies (2025), available at Human rights; NBIM, Sustainability due diligence, available at www.nbim.no/en/responsible-investment/sustainability-due-diligence/.