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Regulatory Focus

Supply Chain Due Diligence

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ESG: SUPPLY CHAIN DUE DILIGENCE

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Regulatory Sources

Global supply chain due diligence covers mandatory and voluntary measures requiring companies to identify, assess, prevent, mitigate, and address adverse impacts in their supply chains. It includes laws, regulations, standards, guidance documents, and international frameworks spanning human rights, environmental, and governance risks across jurisdictions.

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Supply chain due diligence obliges companies to identify, prevent, mitigate, and account for human rights and environmental risks across operations, subsidiaries, and value chains.

Companies are expected to implement and maintain robust due diligence processes that address human rights and environmental impacts throughout their operations and value chains. Key requirements typically include:

  • Embedding due diligence into corporate policies and governance systems
  • Identifying actual and potential adverse human rights and environmental impacts
  • Taking appropriate measures to prevent, mitigate, or remediate those impacts
  • Establishing accessible grievance mechanisms
  • Monitoring the effectiveness of due diligence measures
  • Reporting publicly on due diligence processes and outcomes
We cover binding due diligence laws, reporting frameworks, and product- or sector-specific regulations that impose human rights and environmental responsibilities across global value chains. Our coverage spans mandatory, national, and international instruments, as well as related reporting standards and guidance documents that shape compliance expectations, enforcement mechanisms, and corporate accountability.

Our coverage includes, but is not limited to:

  • EU: Corporate Sustainability Due Diligence (CSDDD), Directive (EU) 2024/1760
  • EU: Sustainability Reporting Standards (ESRS), Regulation 2023/2772
  • EU: Corporate Sustainability Due Diligence (CSDDD), Directive (EU) 2024/1760 and Other – Amendment – (on postponement of deadlines for corporate sustainability reporting and due diligence requirements) Directive (EU) 2025/794  (Stop-the-Clock Amendment)
  • EU: Corporate Sustainability Due Diligence (CSDDD), Directive (EU) 2024/1760 and Others – Amendment – (on reducing companies in scope and deleting sector specific ESRS requirement) Directive (EU) 2026/470 (Omnibus Content Amendment)
  • EU: Omnibus Package, Q&A Document, February 2025
  • EU: Batteries and Waste Batteries, Regulation (EU) 2023/1542
  • EU: Batteries and Waste Batteries, Regulation (EU) 2023/1542 – Amendment – (on postponing the application date of battery due diligence obligations by 2 years) Regulation (EU) 2025/1561
  • EU: Making Available on the Union Market and Export from the Union of Certain Commodities and Products Associated with Deforestation and Forest Degradation, Regulation (EU) 2023/1115
  • EU: Making Available on the Union Market and Export from the Union of Certain Commodities and Products Associated with Deforestation and Forest Degradation, 
  • Regulation (EU) 2023/1115 – Amendment – (on delay and simplified measures for small enterprises) Regulation (EU) 2025/2650
  • EU: Prohibiting Products Made with Forced Labour on the Union Market, Regulation (EU) 2024/3015
  • France: Duty and Vigilance of Parent and Subcontracting Companies, Law No. 2017-399
  • Germany: Corporate Due Diligence In Supply Chains Act, BGBl. 2959, 2021
  • Germany: Corporate Due Diligence In Supply Chains Act, BGBl. 2959, 2021 – Proposed Amendment – (on reporting and penalties) Draft Law, August 2025
  • GRI: Corporate Sustainability Due Diligence Policies and Sustainability Reporting, Report, March 2023
  • Netherlands: International Corporate Responsibility, Draft Act, November 2024
  • Norway: Business Transparency and Work on Fundamental Human Rights and Decent Working Conditions, Act No. 99, 2021
  • Sweden: Due Diligence in the Supply Chain, Regulation SFS 2020:1187
  • Switzerland: Due Diligence Obligations and Transparency Regarding Minerals and Metals from Conflict Areas and Child Labour, Ordinance, December 2021
  • UK: Modern Slavery Act, 2015
  • UK: Slavery and Human Trafficking in Supply Chains, Guidance Document, March 2025
  • Australia: Strengthening the Modern Slavery Act, Consultation Paper, July 2025
  • Canada: Fighting Against Forced Labour and Child Labour in Supply Chains Act, c. 9, 2023
  • USA: Prevention of Forced Labor in Xinjiang Uyghur (UFLPA), House Bill 6256 Enacted, 2021
  • USA: Prohibition on Participation in Foreign Sustainability Due Diligence Requirements, Senate Bill 985, 2025
  • Colombia: Human Rights Framework for Companies, Draft Law, July 2025
  • Brazil: National Framework for Human Rights and Business, Bill PL 572/2022
  • South Korea: Human Rights and Environmental Protection for Sustainable Corporate Management, Draft Law, November 2025
  •  ILO: Combating Forced Labour: A Handbook for Employers and Business, Guidelines, November 2025
  • OECD: Multinational Enterprises on Responsible Business Conduct in a Global Context, Guidance Document, June 2023

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Frequently Asked Questions

  • Mandatory supply chain due diligence laws typically apply to large corporations that meet specific thresholds regarding their annual turnover and total number of employees. While most supply chain due diligence frameworks target large corporations, smaller entities may find themselves indirectly affected as they are asked by their larger corporate partners to provide information on their operations. Certain sector-specific due diligence rules focusing on forest products or batteries often also capture smaller companies.

  • Voluntary standards such as the UN Guiding Principles and OECD Guidelines describe what responsible human rights and environmental due diligence should look like, but they are not directly enforceable by regulators. Many new laws explicitly build on these frameworks and “hard‑wire” their concepts into legislation, turning previously soft‑law expectations into legal duties for companies within scope. As a result, companies that already followed UNGP/OECD approaches are often better prepared to comply with emerging statutory requirements.

  • While the primary focus of many supply chain due diligence laws is on companies headquartered within the regulating jurisdiction, the CSDDD extends its scope to foreign firms that generate at least 1.5 billion net turnover annually in the EU, forcing global entities to align their entire international operations with European human rights and environmental standards.

  • Companies are expected to embed due diligence into policies and governance, identify and assess human rights and environmental risks in their operations and value chains, take measures to prevent or mitigate adverse impacts, provide grievance mechanisms, monitor effectiveness, and publicly report on actions and outcomes, often aligned with EU sustainability reporting standards.

  • Sanctions range from administrative fines based on turnover, through confiscation of non‑compliant products or revenues, to exclusion from public procurement and access to public funding. Some frameworks, like France’s Duty of Vigilance Law and the CSDDD, also open the door to civil liability claims if companies fail to meet their due diligence obligations and harms occur. In parallel, trade‑based measures such as bans on products made with forced labour or linked to deforestation give authorities the power to stop goods at the border.

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