Why it matters
Germany's Supply Chain Act, the EU Corporate Sustainability Due Diligence Directive and forced-labour import rules require companies to identify and address human-rights and environmental risks in their supply chains. Evidence is becoming as important as policy.
Requirements are moving from statements of intent to evidence of action. Companies are expected to show how they identify risks, prioritise them, act on them and track the results, and how they involve affected stakeholders.
By the numbers
5,000employees and €1.5bn turnover: the new CSDDD thresholds for EU companies 1
26 Jul 2029date from which in-scope companies must comply 1
What's changing
- Risk assessments are expected to cover direct and, increasingly, indirect suppliers.
- Authorities and customers expect documented remediation and grievance mechanisms.
- Import controls can block goods linked to forced labour.
How leaders are responding
- Using risk-based prioritisation to focus audits on high-risk suppliers and regions.
- Combining supplier questionnaires with independent data sources.
- Assigning clear ownership across procurement, legal and sustainability teams.
What good looks like
- A risk-based map of the supply chain beyond tier one
- Supplier audits and remediation plans tied to the highest risks
- One evidence file that serves due diligence, customs and customer requests
What to watch
- Changes to the CSDDD timetable and scope under the EU simplification agenda.
- Enforcement of forced-labour import rules.
- Supply chain mapping tools that reach beyond tier one.
Where to start
Combine procurement, sustainability and legal data into one view of supplier risk, and focus first on the highest-risk categories.
Questions for your leadership team
- Which suppliers present our highest human-rights and environmental risks?
- Could we evidence our due-diligence process to an authority?
- How can affected people raise concerns with us?
