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Elegant corporate meeting room in a luxury hotel with garden view
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Implementing the Corporate Sustainability Due Diligence Directive in the Hospitality Industry

4 min read

This article was originally published in July 2023 while the Corporate Sustainability Due Diligence Directive was a proposal. Regulatory update, October 2026: Directive (EU) 2024/1760 has since been adopted and amended by the Omnibus I legislation, including Directive (EU) 2026/470. Member States must transpose the amended CSDDD by 26 July 2028 and apply the measures from 26 July 2029; the Article 16 reporting measures apply for financial years starting on or after 1 January 2030. The discussion below concerns hospitality procurement planning, not a finding that every hotel is directly subject to the directive.

Direct CSDDD duties depend on the relevant company or group, its turnover and employee thresholds, and the applicable national implementation. The amended general EU-company threshold is more than 5,000 employees on average and more than EUR 1.5 billion net worldwide turnover; non-EU companies have a separate EU-turnover test, and qualifying group, franchising and licensing arrangements also need assessment. Smaller hotels may receive proportionate information requests as business partners without being directly in scope. Companies in scope must identify and address actual and potential adverse human rights and environmental impacts through a risk-based due diligence process.

Understanding the Directive in Relation to Hospitality

For hospitality procurement planning, purchasing, supplier relationships and waste handling are useful areas to examine. Hotels rely on numerous suppliers for food, beverages and other amenities, so fair labour practices and environmental risks deserve attention. These practical priorities do not establish that every hotel or every supplier is directly covered by CSDDD; an in-scope company must assess its actual and potential adverse impacts within the directive's relevant chains of activities.

Illustrative hotel lobby with a living green wall; not evidence of ESG compliance

Illustrative hotel design integrating greenery into a guest space; the image does not establish a real ESG certification

Practical Consequences

Hotels can develop sustainability strategies that address environmental impacts, labour practices and community involvement. Reducing greenhouse gas emissions, minimising waste and conserving water are possible operational initiatives, not a universal CSDDD compliance checklist. The amended CSDDD does not retain the former mandatory climate-transition-plan obligation. Applicable due diligence duties concern the company's specific human rights and environmental risks and require the relevant entity and national rules to be assessed.

Hospitality establishments might need to invest in energy-efficient infrastructure, transition toward renewable energy sources, and establish recycling and waste reduction programs. They may also need to collaborate with their suppliers to ensure that their practices align with the sustainability objectives of the business.

Hotels may choose to improve employee training, diversity and inclusion, working conditions and community involvement as part of responsible operations. These initiatives should be distinguished from the specific human rights due diligence duties that apply to companies within CSDDD's scope.

Hotel restaurant buffet featuring locally sourced organic produce and sustainable food practices

Illustrative locally sourced organic food: a procurement choice, not proof of CSDDD compliance

Opportunities Ahead

While implementing the directive may add complexity to business operations, it also presents a significant opportunity. A growing number of consumers are actively seeking out businesses that align with their values. Research has indicated that many travelers are willing to pay more for accommodations that prioritize sustainability.

By embracing this directive, hospitality businesses can distinguish themselves within a competitive market, enhance customer loyalty, and potentially experience financial benefits.

The Corporate Sustainability Due Diligence Directive goes beyond being another regulation; it serves as a call to action for the hospitality industry to wholeheartedly embrace its role in fostering a sustainable and socially equitable world.

By approaching this task with a dedicated mindset, businesses have the opportunity to not only meet regulatory requirements but also contribute to a better future for everyone.

The implementation of the Corporate Sustainability Due Diligence Directive is a milestone in fostering sustainable and socially conscious businesses. In the hospitality industry, which has a considerable environmental impact and significant social consequences, this directive holds immense potential to drive meaningful positive transformations. By embracing the essence of the directive and committing to responsible practices, businesses operating in this sector can play a vital role in creating a more sustainable and fair world.