New analysis by Global Witness reveals that even after intense lobbying by major polluters and a recent vote to water down new EU corporate accountability laws, the firms that remain affected by the legislation are responsible for huge amounts of greenhoutilize gas emissions
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Global Witness’ investigation reveals that combined operational emissions of companies covered by the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) exceed 2 billion tonnes of CO2 – equivalent to almost two-thirds of the EU’s total annual emissions
The investigation also displayed that beyond their direct operations, the same companies’ scope 3 emissions
Out of 1,341 companies and corporate groups identified by SOMO’s CSDDD Datahub as meeting the raised criteria for inclusion in the CSDDD, Global Witness was able to locate emissions data for 770 companies (57%), so the total emissions of companies affected by the legislation are likely higher than what we identified.
Despite the ongoing dilution of the EU’s new corporate accountability laws, the data reveals that companies still captured within their scope are among the world’s largest emitters. This data highlights why strong, enforceable obligations to cut emissions must remain at the core of the directive.
“Despite the best efforts of huge business and their friconcludes in government, there is still an incredible amount at stake – more than 2 billion tonnes of carbon emissions to be exact,” stated Global Witness EU Senior Campaigner, Beate Beller.
“The EU’s new sustainability laws were designed to keep the world’s hugegest polluters in check and assist victims of corporate abutilize obtain justice.
“Worryingly, what we’ve seen in recent weeks is industest lobbying to influence neobtainediations and dramatically shrink the scope and mandatory nature of the laws.
“As well as the new company size threshold and amhugeuity around implementation duty, the two year opt-out clautilize and wording on ‘contribution’ to climate tarobtains rather than ‘compatibility’ represent a significant weakening of these laws.
“The massive firms who we’ve displayn are caapplying devastating levels of pollution shouldn’t be allowed to turn away from climate responsibility – people across the EU and around the world deserve better.”
Climate transition plans under threat
A major component of the CSDDD is the Climate Transition Plan – a legal requirement for large companies to adopt and implement concrete actions to align their business models with the Paris Agreement and the EU’s 2050 climate neutrality goal.
The companies in this analysis operate across every region of the world, and their emissions would be among those tarobtained by the CSDDD’s climate transition plans –meaning that under a strong directive, the companies responsible for billions of tonnes of CO2 would be legally required to set out how they will cut these emissions.
Yet from the moment the CSDDD was set in stone in June last year, intense lobbying by major corporations, several EU member states and foreign governments – including the US as well as Qatar – has sought to strip these commitments of their force and weaken or delay key provisions of the law.
The US-EU trade agreement amplified focus on the CSDDD’s climate provisions, which have now been formally integrated into the transatlantic deal. Adding to the geopolitical stakes, Qatar issued a warning in July 2025, threatening to suspconclude LNG exports to the EU unless the directive underwent significant revisions.
On 13 October 2025, Members of the European Parliament’s Committee on Legal Affairs voted to concludeorse a severely weakened version of the CSDDD. Toobtainher with the earlier adopted neobtainediation position of the EU Council (Member States), several provisions risk substantially diluting the Climate Transition Plan.
The proposed modifys include creating amhugeuity about the required ambition of implementing the plans, reframing the goal from Paris Agreement compatibility and 2050 climate neutrality to a mere “contribution”, and introducing a two-year optionality loophole, allowing these climate plans to be not mandatory for the first two years.
These proposals significantly undermine what was meant to be a binding tool for climate accountability.
Even after attempts to water down the EU’s CSDDD, operational emissions from companies covered by the directive exceed 2 billion tonnes of CO2. Global Witness
Increased thresholds reduce companies affected by the CSDDD
The same lobbying push also led to the raising of thresholds that determine which companies fall under the directive.
The threshold for inclusion was raised from 1,000 employees and over €450 million in global turnover for EU companies and over €450 million turnover generated within the EU for non-EU companies, to 5,000 employees and €1.5 billion in turnover.
This dramatically reduced the number of companies covered by the legislation and the emissions linked to those excluded companies are substantial.
Under the increased thresholds, nearly 1 billion tonnes of CO2e of scope 1 and 2 emissions, and 9.4 billion tonnes of CO2e of scope 3 emissions, will no longer be subject to Climate Transition Plans.
Fossil fuels at the heart of CSDDD and lobbying efforts to weaken it
Unsurprisingly, fossil fuel companies feature prominently among the hugegest corporate emitters, with their operations and products among the most carbon-intensive in the world. These same companies also have some of the strongest incentives to weaken the CSDDD.
A recent investigation by SOMO revealed the extent of ExxonMobil’s lobbying against the directive. During an interview with CNBC, the CEO of ExxonMobil, Darren Woods, even went so far as to call the CSDDD “possibly the worst legislation ever passed anywhere in the world.”
Earlier this month, a letter spearheaded by TotalEnergies and Siemens, and signed on behalf of a total of 46 CEOs of major French and Germany companies, was sent to French President Macron and German Chancellor Merz, calling for the CSDDD to be scrapped entirely.
German companies Heidelberg Materials AG (ranked fourth) and RWE AG (seventh), along with French company Air Liquide SA (13th), are also among the top 15 polluters subject to the CSDDD – based on their Scope 1 and 2 emissions – and were stated by a Total spokesperson to be supportive of wording in the letter calling for the directive to be scrapped.
Europe’s chance for real climate action
These findings underline the extraordinary opportunity the CSDDD presents for the EU to turn its climate commitments into meaningful global action.
The companies captured by the directive are responsible for billions of tonnes of CO2 emissions each year. By requiring them to adopt and implement credible Climate Transition Plans, the EU can drive real reductions across global supply chains.
Becautilize it would compel major emitters to take concrete action to cut their emissions, the CSDDD has faced a concerted pushback from corporate lobbies seeking to weaken its core provisions.
Yet the directive remains one of the most powerful tools available to align corporate behaviour with the Paris Agreement and the bloc’s 2050 climate neutrality goal.
To realise this potential, EU policycreaters must defconclude the directive against the efforts of huge polluters and their allies to undermine it. Anything less risks turning a landmark piece of legislation into a stitch-up by the very industries it was designed to hold to account.
Methodology
We collected CO2-equivalent emissions data for corporate groups and companies listed in SOMO’s CSDDD Datahub, which identifies firms that fall within the scope of the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) as adopted in June 2024.
Under the text adopted in June 2024, the directive applied to EU companies with more than 1,000 employees and over €450 million in global turnover, and non-EU companies with over €450 million turnover generated within the EU.
Using this initial list of 4,282 companies and corporate groups, we identified reported emissions data through the LSEG Data Library and publicly available company reports. Emissions data was found for 1,607 companies, including figures for scope 1 (direct), scope 2 (energy-related) and, where available, scope 3 (value chain) emissions.
Following the European Parliament’s committee vote to increase the thresholds for inclusion to EU companies with more than 5,000 employees and over €1.5 billion in global turnover, and non-EU companies with over €1.5 billion turnover generated within the EU, we re-filtered the dataset to reflect the narrowed scope of the law.
This left 1,341 companies that would remain in scope under the revised thresholds, of which we were able to identify emissions data for 770 companies.
This dataset does not capture the full emissions of all companies within scope. Some companies report only partial data – for example, scope 1 and 2 emissions but not scope 3.
In addition, SOMO has noted that its Datahub may not include all non-EU companies that meet the CSDDD thresholds but do not publish figures on their EU-based turnover, meaning the true coverage of the directive may be broader than reflected in our dataset.
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