Please find attached the comments by Shift, which focus on the following elements: 1. Maintain the improved metric on adequate wages in S1 which is feasible for companies to implement and which will yield comparable and decision-useful information for investors and other stakeholders 2.
SHI
Shift
NGO · United States · EU Transparency Register 017407241307-21
3
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1106 non-governmental organisations on this site, they rank #484 by legislative files engaged, a count of participation, not a measure of influence.
2
declared lobbying FTE
self-declared
–
declared costs / yr (floor)
1
EP accreditations
as declared to the register
2021
in the register since
Declares membership of
- Member, AIM-Progress Advisory Board
- https://aim-progress.com/about-us#governance
- Member, Alliance for Corporate Transparency
- https://www.allianceforcorporatetransparency.org/
- Member, Business Commission to Tackle Inequality
- https://tacklinginequality.org/our-commissioners/
- Member, Capitals Coalition Board
- https://capitalscoalition.org/the-coalition/the-board/
- Member, EFRAG Sustainability Reporting Board
- https://www.efrag.org/en/about-us/governance/efrag-sustainability-reporting-board
- Member, Investor Alliance for Human Rights (IAHR) Advisory Council
- https://investorsforhumanrights.org/advisory-council
- and 4 more
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Non-governmental organisations
- Registered as
- Shift Project Limited (Shift)
- Head office
- New York, United states
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Shift filed 3 positions between 20 May 2022 and 2 Jun 2026, across 3 of the 665 legislative files tracked here, attaching a full position paper 2 times.
2022 · 1 filed2025 · 1 filed2026 · 1 filed
What they argued
Shift strongly welcomes the proposal for a draft Directive on Corporate Sustainability Due Diligence. The initiative is an opportunity with few parallels in its potential to drive sustainability into the heart of how business gets done.
The ESRS include a number of datapoints that reference SFDR social indicators so that financial market participants are able to comply with SFDR by relying on public data reported by real economy companies in line with the CSRD.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
Showing 5 of 128.
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Everything on this page comes from Shift’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.