Energy companies impacted by EU sustainability regulation CS3D – a compliance checklist

The EU’s Corporate Sustainability Due Diligence Directive (“CS3D”) came into force on 25 July 2024 and imposes significant obligations on large companies based inside as well as outside of the EU, including those in the energy sector, that generate substantial turnover within the EU. These companies must now conduct comprehensive and extensive due diligence to identify, prevent, and mitigate adverse environmental and human rights impacts across their operations and value chains. Failure to comply carries risk of significant fines and claims being brought against non-compliant entities.

For energy companies headquartered outside the EU in particular, compliance with the CS3D presents both challenges and opportunities. Mayer Brown has prepared a 10 point checklist to assist the General Counsel of non-EU energy companies in navigating these complexities.