NETHERLANDS Law and Practice Contributed by: Manon Cremers, Heleen Kersten, Frédérique van der Wegen and Sandra Rietveld, Stibbe
this deadline. On 13 January 2025, a bill for the CSRD implementation was submitted to the Dutch Lower House. CSDDD On 23 February 2022, the European Commission published the proposal for the CSDDD, which aims to harmonise existing EU member state laws on supply chain due diligence, obligations regarding actual and potential human rights adverse impacts and environmental adverse impacts with respect to their own operations and those of their subsidiaries and other entities in their value chain. The directive entered into force on 25 July 2024 and must be implemented by member states by July 2026. On 18 November 2024, a draft bill to implement the CSDDD in the Netherlands was published for consultation. Omnibus Packages On 26 February 2025, the European Commission adopted a package of proposals in the form of two omnibus packages aimed at simplifying ESG regulations in the EU, whilst boosting competi - tiveness. These proposals include amendments to the CSRD and CSDDD to reduce regulatory burdens and give companies additional time to prepare for compliance. On 3 April 2025, the European Parliament, having used a fast-track procedure, voted to approve the directive that included those amendments and postponed reporting and due diligence obligations under the CSRD and CSDDD. This “stop-the-clock” directive entered into force on 17 April 2025. See 2.2 Environmental, Social and Governance (ESG) Considerations for more information on the proposed amendments to the CSRD and CSDDD in the omnibus packages. CG Code The main theme of the CG Code 2022 is sustain - able long-term value creation. On 20 March 2025,
the CG Code was updated. This update relates in particular to the risk management statement ( Verklaring Omtrent Risicobeheersing ). Under the updated CG Code, the management board of a company must declare the following in its management report. First, that internal risk man - agement and control systems provide at least a limited level of assurance. Second, that the sus - tainability reporting does not contain any mate - rial misstatements. Third, the level of assurance these systems provide that the operational and compliance risks are controlled effectively. The risk management statement serves to provide transparency to stakeholders on the manage - ment of operational, compliance and reporting risks. See 1.2 Sources of Corporate Govern- ance Requirements for more information on the CG Code. Milieudefensie/Shell See 4.7 Responsibility/Accountability of Direc- tors for further information regarding these cas - es. Milieudefensie/ING On 28 March 2025, Dutch environmental group Milieudefensie, filed a lawsuit against ING, alleg - ing that the bank failed to meet its climate obli - gations (ie, to cut its total emissions in half and stop working with companies with high pollution levels). The lawsuit demands that ING halves its total emissions by 2030 compared to 2019 levels and implements stricter climate policies across eight high-pollution sectors, including steel and aviation. Milieudefensie, also calls for ING to stop financing companies involved in new oil and gas projects and to require all large cor - porate clients to submit credible climate transi - tion plans. The NGO argues that ING’s current approach is insufficient in addressing its climate impact, despite the bank’s claims of prioritising
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