SVI responds to CSDDD and TISFD: our positions and how to get involved
SVI has submitted responses to two consultations with significant implications for how people-related impacts are measured, managed and disclosed: the European Commission's guidelines for implementing the Corporate Sustainability Due Diligence Directive (CSDDD), and the Taskforce on Inequality and Social-related Financial Disclosures (TISFD) Beta Framework v0.1.
The CSDDD guidelines will inform how large companies are held accountable for harm in their value chains. TISFD will shape how businesses and financial institutions disclose their impacts on people and inequality. Both touch on territory central to SVI's work, and we had substantive things to contribute to each. The positions we have taken reflect input gathered from across our global network of practitioners and national networks.
Our response to the CSDDD
Our central argument is that effective due diligence is a management system, not a reporting exercise. The risk with implementation guidelines is that they produce longer checklists rather than better decisions, and we want to ensure they point companies towards a systems-and-decisions approach instead.
Specifically, we argued that:
The guidelines should direct companies towards a recognised, auditable management system, not more paperwork. The SDG Impact Standards and forthcoming ISO-UNDP 53001/2 provide a repeatable, interoperable way to identify, prevent, mitigate and remedy adverse impacts.
Stakeholder engagement must drive materiality, not follow it. Severity should be assessed from the perspective of those affected, using wellbeing as a common measure.
SVI's Principles of Social Value map directly onto the CSDDD due diligence cycle, and SVI’s flagship campaign, the True & Fair Project, makes the case that the harm companies cause and their duty to remedy it are already relevant to users of the accounts under existing law.
The consultation remains open until 14 August 2026 (midnight Brussels time). If you would like to submit your own response, you are welcome to draw from or build on ours. Feedback can be submitted via the European Commission's consultation page.
The following social value networks have endorsed this response as signatories:
Our response to TISFD
The TISFD Framework represents an important step towards making inequality and people-related impacts visible in mainstream disclosure. We responded in a spirit of strong support, while identifying gaps that matter.
Our headline concern is this: under the current draft, an entity could comply with the Framework without ever hearing from anyone experiencing its impacts. Stakeholder engagement has no quality bar, and engagement with affected stakeholders at the materiality stage is optional. This is a gap worth addressing, particularly in a framework focused on inequality and its impacts on people.
Our key recommendations were that the Framework should:
Require the perspectives of affected stakeholders as an input to materiality assessment, and not just describe engagement as something that may happen.
Recognise affected stakeholders as users of disclosed information, not only as sources of data. Disclosure to affected people is what turns measurement into accountability.
Provide a clear method for determining the relevance and significance of impacts -- and ground metrics in outcomes experienced by people, not outputs generated by organisations.
Strengthen the treatment of remedy, so that disclosure captures not only what grievance channels exist, but whether harm was actually addressed.
As with CSDDD, you are welcome to draw from or build on our response for your own submission. The TISFD consultation closes 31 July 2026 - feedback can be submitted directly via TISFD's interactive platform.
The following networks have endorsed this response as signatories:
Social Value Network South Africa (SVNSA)
Social Value West Africa.