Since the endorsement of the UN Guiding Principles on Business and Human Rights (UNGPs) by the UN Human Rights Council in 2011, several legislative processes have been initiated to make corporate human rights and environmental due diligence mandatory. One of the most recent and significant examples of this is the EU Corporate Sustainability Due Diligence Directive (CSDDD), a framework which aims to create legally binding obligations for companies based or active in the EU regarding the impact of their activities throughout their value chains. This legislative process was formally initiated in February 2022, when the European Commission published a proposal for a Directive. In parallel to advocating with EU institutions and representatives to ensure the highest possible level of human rights and environmental protection. This Coalition has expressed concerns roach for and the Coalition approach as two different approaches to EU due diligence legislation. It aims to answer the following research question: which of these two approaches constitutes a stronger framework for corporate accountability?

This thesis is based on the experience of a traineeship at the European Center for Constitutional and Human Rights (ECCHR), a member of the aforementioned civil society coalition. It builds on the concept of corporate accountability, which is conceptualised into an analytical framework, based on an existing framework by Bernaz (2020). The concept is broken down into seven dimensions - personal scope, beneficiaries, material scope, legal force, due diligence obligation, enforcement, and reparations. By analysing each approach through the prism of this analytical framework and proceeding to a comparative analysis, this thesis outlines key differences between the two approaches and situates them on a spectrum of corporate accountability. As a background for these analyses, this thesis presents a literature review on the concept of corporate accountability, as well as a state of the evolving policy field of due diligence.