Your customer or buyer is asking for ESG information about South Sudan supply chains. Here is what the regulatory environment requires — and what international buyers need from you.
South Sudan is the world's youngest country, having gained independence from Sudan in 2011. It has significant oil reserves — oil accounts for approximately 90% of government revenues. South Sudan has experienced devastating civil conflict since 2013, with a peace agreement signed in 2018 but fragile implementation. The country is classified as a Fragile and Conflict-Affected State (FCAS) by the World Bank. ESG compliance in South Sudan is primarily relevant for international oil companies operating there (TotalEnergies, Petronas, CNPC) and for buyers of conflict minerals. South Sudan is not a significant supplier to EU markets beyond oil, but companies with any South Sudanese supply chain exposure face heightened CSDDD due diligence requirements.
Key regulations in South Sudan — ESG Supplier Guide
EU CSDDD — Enhanced Due Diligence for Conflict-Affected Areas
South Sudan is classified as a conflict-affected and high-risk area under EU CSDDD. EU companies with any supply chain exposure to South Sudan must conduct enhanced human rights and environmental due diligence. Key ESG risks include: conflict financing through oil revenues, human rights abuses in oil-producing regions, environmental damage from oil spills and flaring, forced displacement of communities, and governance under a fragile peace agreement.
EU CSRD — Oil & Gas Supply Chains
TotalEnergies has significant oil interests in South Sudan (Block B). As a major EU-listed company, TotalEnergies must report on its South Sudan operations under CSRD. Key ESG issues include: conflict risk, community rights, environmental management of oil operations, and human rights due diligence in a conflict-affected area.
OECD Due Diligence Guidance — Conflict Minerals
South Sudan is classified as a conflict-affected and high-risk area under the OECD Due Diligence Guidance. Any minerals sourced from South Sudan — including gold — require enhanced due diligence under the OECD framework. EU companies sourcing minerals from South Sudan face CSRD supply chain reporting requirements and CSDDD enhanced due diligence obligations.
EU Methane Regulation — Oil & Gas Flaring
South Sudan has significant gas flaring associated with oil production — a major source of greenhouse gas emissions and a key ESG concern. The EU Methane Regulation requires importers of oil and gas into the EU to demonstrate methane emissions standards compliance. Oil companies operating in South Sudan face increasing pressure to reduce flaring.
South Sudan Data Protection & Cyber Obligations
South Sudan does not yet have a comprehensive data protection law or mandatory cyber incident reporting regime. The National Communications Authority (NCA) oversees telecommunications. The ongoing political and security situation significantly affects the operating environment. International buyers from the EU, UK, or USA will assess South Sudanese suppliers against their own data protection standards under CSRD and CSDDD supply chain due diligence. Suppliers should obtain specialist advice before engaging with South Sudanese entities.
What this means for you as a supplier
South Sudan is a high-risk jurisdiction requiring enhanced CSDDD due diligence. Any supply chain exposure to South Sudan — particularly oil, gold, or other minerals — requires enhanced human rights and environmental due diligence under OECD guidelines and EU CSDDD. EU oil companies operating in South Sudan face CSRD reporting requirements. Gas flaring is a critical ESG issue. The fragile peace agreement and ongoing conflict risk require continuous monitoring.
Key dates
FY2024 (ongoing)
CSRD — large EU companies must report on supply chain sustainability including South Sudan operations
July 2029
CSDDD Phase 1 — largest EU companies must conduct enhanced supply chain due diligence for conflict-affected areas including South Sudan
High-risk jurisdiction: enhanced due diligence required
South Sudan is classified as a Fragile and Conflict-Affected State (FCAS) by the World Bank and as a conflict-affected and high-risk area under the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals. The country has experienced devastating civil conflict since 2013, with an estimated 400,000 deaths and 4 million displaced. A peace agreement was signed in 2018 but implementation remains fragile. Human rights organisations have documented serious abuses in oil-producing regions, including forced displacement of communities, sexual violence, and use of oil revenues to fund armed groups. EU companies with any supply chain exposure to South Sudan — including through financial investments in oil companies operating there — face enhanced CSDDD due diligence requirements. The OECD Due Diligence Guidance requires companies to conduct a conflict analysis, identify and assess risks, and implement risk mitigation measures before sourcing from South Sudan.
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
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