Evolving State Expectations on Company Due Diligence and Public Reporting
In recent years, a number of States have developed new regulations with respect to corporate due diligence and company reporting, as well as modern slavery and
forced labour. The legislative landscape is constantly evolving but the following examples are noteworthy as of September 2026. Note the below list is not exhaustive. In addition to the below, some lawmakers in other countries such as Mexico, South Korea, Thailand and Indonesia are considering mandatory human rights due diligence legislation. Japan has issued Guidelines on Respecting Human Rights in Responsible Supply Chains (2022).
Australia
The Australian Modern Slavery Act (2018) requires companies with consolidated revenue greater than AUS100 million to publish an annual statement about the slavery risks in their operations and what they are doing to assess and reduce those risks. The statement also needs to include a similar assessment of their supply chain. It was amended in 2024 toestablish an independent Australian Anti-Slavery Commissioner for victims and survivors, business and civil society to engage on issues and strategies to address modern slavery. As of July 2026, following a 2024 independent review, the Government announced its intention to strengthen the law with a new criminal offence where companies with an annual consolidated revenue over $100 million fail to prevent modern slavery in their supply chains.
Canada
The Fighting Against Forced Labour and Child Labour in Supply Chains Act (2023) requires certain companies doing business in Canada to report annually on the measures they are taking to prevent and reduce risks of forced labour and child labour in their supply chains. In 2026 the government introduced Bill C-35 (the Ban
on Importing Goods Made with Forced Labour Act), consulted on its implementation and also consulted on potential mandatory due diligence measures concerning labour rights in supply chains.
European Union
Several trade-related regulations concerning raw materials have been adopted by the EU in recent years which require human rights due diligence in supply chains if commodities are to be placed on the European Union market.
The EU Regulation on Conflict Minerals (applicable from 1st January 2021) sets out due diligence obligations for the so-called “upstream” part of the mineral supply chain, which includes those who import raw materials (specifically tin, tungsten, tantalum, gold (3TG) to smelting and refinery plants in the EU. For “downstream” companies that use refined forms of these metals and minerals from conflict areas in components and goods, the European Commission will soon release an online platform where downstream companies can voluntarily share information on their due diligence for metals and minerals.
In 2023, the EU Batteries Regulation entered into force, replacing the 2006 Batteries Directive. This Regulation, which comes into effect in stages, aims to make batteries sustainable throughout their lifecycle. Companies placing batteries on the EU internal market will have to demonstrate that the materials used for their manufacturing were sourced responsibly. This means that social and environmental risks associated with the extraction, processing and trading of the raw materials used for battery manufacturing (such as lithium and cobalt) will have to be identified and mitigated. Due diligence obligations on responsible sourcing, processing, and trading of cobalt, natural graphite, lithium, and nickel were postponed in 2025 from August 2025 to August 2027, and guidance is awaited.
Further information on implementation is available on the European Commission website.
The EU Deforestation Regulation (EUDR), which repealed the EU Timber Regulation, covers operators and traders that import cattle, wood, cocoa, soy, palm oil, coffee, rubber, and some of their derived products. They must implement mandatory due diligence processes to avoid contributing to deforestation and reduce carbon emissions. After the implementation deadline, it will be prohibited to place relevant products on the EU market, or export them from the EU, unless they are: 'deforestation-free' (which means that the relevant products contain, have been fed with or have been made using, relevant commodities that were produced on land that has not been converted from forest to agricultural use, whether human-induced or not, after 31 December 2020); produced in accordance with the relevant legislation of the country of production; and covered by a due diligence statement indicating no more than a negligible risk of non-compliance. Implementation has been twice delayed, and will apply from 30 December 2026 for large and medium-sized companies, and 30 June 2027 for micro and small enterprises.
In November 2024, the EU adopted the Forced Labour Regulation. This bans products being placed on the EU market after 13 December 2027 if they have been made using forced labour, defined in accordance with ILO conventions as "all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily". Forced labour has been identified in a number of raw material supply chains, including minerals and agricultural products.
The European Commission will establish a non-exhaustive database of forced labour risks indicating where there is reliable and verifiable evidence that products produced by a specific economic sector in particular geographic areas present a higher risk of being made with forced labour. Based on an assessment of possible risks, Commission (for forced labour outside the EU) or member state authorities (for forced labour within their territory) may initiate an investigation if there is a suspected violation. Further information is available on the Commission’s Forced Labour Single Portal.
In 2026, following the consideration of the 2025 ‘Omnibus I’ package intended to simplify sustainability regulation, amendments were adopted to the 2022 Corporate Sustainability Reporting Directive (CSRD), and the 2024 Corporate Sustainability Due Diligence Directive (CSDDD).
The CSRD replaced elements of the 2014 Non-Financial Reporting Directive (NFRD) and requires large companies and listed companies to publish regular reports on the social and environmental risks they face, and on how their activities impact people and the environment, in accordance with European Sustainability Reporting Standards (ESRS) which are under simplification. More details are available here.
The CSDDD requires companies with 5,000+ employees/€1.5bn net turnover (worldwide for EU companies, in the EU for non-EU companies) to identify and address actual and potential adverse human rights and environmental impacts in their own operations, those of their subsidiaries and in their chains of activities, focussing on areas where impacts are most likely and most severe, based on reasonably available information. Member States must adopt national laws by July 2028 for application from July 2029. Guidance on a number of elements, including multistakeholder and certification initiatives, and model contractual clauses, is awaited. Further details are available here.
France
The French loi de vigilance (2017) requires companies companies headquartered in France with 5,000 or more employees in France or 10,000 employees worldwide (including through direct and indirect subsidiaries) to establish mechanisms to prevent human rights violations throughout their supply chain. They must provide an overview of measures taken pursuant to a “vigilance” plan in relation to human rights and fundamental freedoms in their annual reports. The publicly available vigilance plan must explain the implementation of risk evaluation procedures and mitigation actions taken, if any. The plan should discuss the business and disclose its subsidiaries, established suppliers, and contractors.
Third parties can apply for an injunction requiring a company implement a “vigilance” plan. Companies could be subject to liability if individuals harmed by a company’s failure to establish or implement a plan seek damages for corporate negligence.
The law is likely to be amended as part of France’s national transposition of the CSDDD.
Germany
The German Supply Chain Due Diligence Act (2021) which came into effect in 2023, places environmental and human rights supply chain due diligence obligations on enterprises to with at least 3,000 employees in Germany (from 2024, with at least 1,000). Implementation of the Act is currently reduced in scale and it is expected to be repealed as part of Germany’s national transposition of the CSDDD (see above).
Norway
Norway's Transparency Act (2022) requires certain companies to carry out due diligence activities to ensure they are operating responsibly, respecting both human rights and decent working conditions. The Norwegian Consumer Authority (NCA) issued updated guidance in December 2025 emphasising the importance of a risk-based approach and meaningful stakeholder engagement.
Switzerland
Article 964 of the Swiss Code of Obligations (Swiss Code) requires companies meeting certain criteria (such as listed companies, banks, insurance companies and others in the financial sector - with 500 or more employees, and a turnover of CHF40 million) to report on non-financial matters, including (but not limited to):
- policies adopted in relation to any climate action goals, social issues; employee-related issues, respect for human rights and combating corruption, including due diligence;
- the measures taken to implement the policies and an assessment of their effectiveness (including performance indicators); and
- the main risks related to the issues above and how the business will address these risks within its own operations and those that arise from its business relationships, products or services.
The Swiss Ordinance on Due Diligence and Transparency (2022) in the Sectors of Minerals and Metals from Conflict Areas and Child Labour (ODDT) sets out due diligence obligations in relation to minerals and metals (tin, tantalum, tungsten, gold (3TG)) from conflict-affected and high-risk areas and in relation to child labour. Does not apply to SMEs. The indicative list of conflict-affected and high-risk areas is provided under EU Regulation 2017/821.
The Swiss Federal Council has undertaken a 2026 consultation on a possible cross-sectoral due diligence and reporting law which may replace these Ordinances and align to the EU CSDDD and CSRD.
United Kingdom
The UK Modern Slavery Act (2015) requires disclosure of activities companies are undertaking to eliminate slavery and human trafficking from their supply chains. It is accompanied by guidance updated in 2025. Statements are available in a government registry. The Immigration and Asylum Bill under discussion in 2026 contains provisions which will strengthen the Act.
Schedule 17 of the UK Environment Act (2021) contains provisions on not placing ‘‘forest risk commodities (FRC)’ (raw or derived products) on the UK market if they were produced on land where use or occupation was illegal under local laws. The prohibition is not yet in force as of 2026, pending implementing regulations. In June 2026 the UK Government announced an intention to consult on these for implementation in 2027. They are expected to mostly align to the EUDR.
United States
Section 1502 of the US Dodd Frank Act (2010) requires persons to disclose annually whether any conflict minerals that are necessary to the functionality or production of a product of the person, as defined in the provision, originated in the Democratic Republic of the Congo or an adjoining country and, if so, to provide a report describing, among other matters, the measures taken to exercise due diligence on the source and chain of custody of those minerals, which must include an independent private sector audit of the report that is certified by the person filing the report.
The Uyghur Forced Labor Prevention Act (UFLPA) (2021) establishes a rebuttable presumption that any goods, wares, articles and merchandise mined, produced or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of the People's Republic of China are prohibited by Section 307 of the Tariff Act (the section which prohibits the importation of any product manufactured, mined or produced using forced or child labour). The accompanying UFLPA Operational Guidance for Importers sets out the types of documentation which the authorities may request if the presumption is to be rebutted, such as documents evidencing a due diligence system and supply chain tracing.
Section 307 of the 1930 Tariff Act prohibits importation of goods of any origin produced wholly or in part with forced labor, and operates through detaining shipments suspected of forced labour using Withhold Release Orders (WROs). The US Customs and Border Protection (CBP) published consolidated Forced Labor Enforcement Operational Guidance in June 2026.