Human rights due diligence (HRDD) is increasingly becoming a legal requirement for companies operating in global markets.
Governments are introducing laws that require businesses to identify, prevent, and address human rights risks across their operations and supply chains. While the details vary by jurisdiction, the direction of travel is clear: due diligence is moving from voluntary practice to mandatory expectation.
This page provides an overview of the evolving HRDD regulatory landscape, what companies are expected to do, and how to respond in practice.
Why human rights due diligence is becoming mandatory
Over the past decade, expectations on business have shifted significantly.
Voluntary frameworks — including the UN Guiding Principles on Business and Human Rights (UNGPs) — established a global standard. Governments are now embedding those expectations into law.
Key drivers include:
- Increased scrutiny of global supply chains
- High-profile cases of labour rights abuses
- Investor demand for stronger risk management
- The need for a level playing field across industries
As a result, companies are now expected not only to commit to human rights, but to demonstrate how they manage risks in practice.
Key features of HRDD legislation
While specific requirements vary, most human rights due diligence laws share common elements.
Companies are typically expected to:
- Identify and assess risks across operations and supply chains
- Take action to prevent and mitigate adverse impacts
- Track effectiveness of their responses
- Provide or enable remedy where harm occurs
- Report publicly on their due diligence processes
These requirements closely reflect the UNGP framework, but with added legal accountability.
The evolving regulatory landscape
European Union
The EU has adopted a comprehensive approach to mandatory due diligence through the Corporate Sustainability Due Diligence Directive (CSDDD - and also known as CS3D).
The CSDDD will require companies to:
- Conduct risk-based due diligence across their operations and value chains
- Integrate due diligence into corporate policies
- Take appropriate measures to prevent and mitigate harm
- Establish complaints and grievance mechanisms
- Monitor and publicly report on implementation
The requirements will apply on a phased basis from 2027 onwards, covering large EU companies and certain non-EU companies operating within the EU market.
National legislation
Several countries have already introduced due diligence or supply chain legislation, including:
- Laws focused on modern slavery reporting
- Requirements for due diligence in specific sectors or risk areas
- Broader human rights and environmental due diligence frameworks
These laws differ in scope and enforcement but are increasingly aligned with international standards.
What this means for companies
The shift to mandatory HRDD has practical implications.
Companies need to move from:
- High-level policy commitments → operational systems
- Periodic reporting → continuous risk management
- Audit-based approaches → risk-based due diligence
Regulators are increasingly focused on whether companies can demonstrate:
- Clear prioritisation of risks
- Evidence of action taken
- Integration into decision-making
- Ongoing monitoring and improvement
Superficial compliance is unlikely to meet these expectations.
Common challenges in responding to legislation
Many organisations face similar challenges when adapting to new requirements:
- Navigating multiple, overlapping regulations
- Translating legal requirements into operational processes
- Aligning internal teams and systems
- Extending due diligence beyond Tier 1 suppliers
- Demonstrating effectiveness, not just activity
Addressing these challenges requires a structured, risk-based approach rather than a purely legal or reporting response.
Building a response: practical steps
Companies preparing for or responding to HRDD legislation should focus on strengthening core systems.
Key steps include:
- Assess current readiness
Review existing policies, processes, and data against legal expectations - Identify gaps
Where are systems incomplete or inconsistent? - Prioritise high-risk areas
Focus first on the most severe risks to people - Strengthen governance and accountability
Ensure clear ownership at senior level - Integrate due diligence into business processes
Particularly procurement, sourcing, and supplier management - Develop robust monitoring and reporting systems
Move beyond compliance metrics toward meaningful indicators
Aligning with international standards
Given the evolving regulatory landscape, many companies benefit from aligning their systems with established international frameworks, including:
- The UN Guiding Principles on Business and Human Rights
- OECD Guidelines for Multinational Enterprises
This provides a consistent foundation that can be adapted to different legal requirements.
In practice, alignment with these frameworks helps reduce fragmentation and future-proofs HRDD systems as legislation continues to develop.
The role of collaboration and guidance
Responding effectively to HRDD legislation is not just a legal exercise. It requires practical insight into supply chains, worker engagement, and operational realities.
Many companies strengthen their approach by:
- Engaging with industry initiatives and peer networks
- Drawing on external expertise and guidance
- Collaborating with trade unions and civil society organisations
- Sharing learning across sectors
ETI’s work in this area highlights the value of combining legal awareness with practical implementation support and stakeholder engagement.
Continue building your HRDD approach
To translate legal requirements into practice:
Human rights due diligence: a complete guide for business
How to implement HRDD in your company
HRDD risk assessment for supply chains
These resources provide step-by-step guidance on building effective due diligence systems.
From compliance to effective due diligence
Mandatory human rights due diligence marks a significant shift in expectations on business.
The most effective responses go beyond compliance. They build systems that:
- Identify and prioritise risks to people
- Integrate due diligence into decision-making
- Enable meaningful action and improvement
Companies that take this approach are better positioned to meet regulatory requirements, manage risk, and demonstrate credible responsible business practice.
