Beyond Compliance

How to design effective mandatory human rights due diligence laws

Executive summary

Between November 2024 and February 2025, Walk Free and Wikirate collected data from corporate disclosures published under Mandatory Human Rights Due Diligence (mHRDD) laws under the Norwegian Transparency Act[i], the French Duty of Vigilance[ii], and the German Act on Corporate Due Diligence Obligations in Supply Chains[iii]. To assess how these legal differences influence the quality of reported business action to combat modern slavery.

Key findings

These findings indicate that, when suitably designed and enforced, mHRDD laws are the gold standard for advancing corporate accountability, going beyond transparency-only models such as MSAs. The varying quality of the statements assessed under Norwegian, German, and French mHRDD laws demonstrate that effectiveness of such laws depends on how the due diligence obligations are drafted and enforced. The following findings indicate which features of mHRDD laws deliver stronger outcomes and highlight where improvements are required.

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1

Specific and detailed obligations drive transparency in mHRDD laws

Legislation must include clear, measurable requirements to yield meaningful transparency:

Embed mandatory disclosure obligations across all key due diligence steps (risk identification, incident reporting, whistleblowing, remediation, prevention efforts).
Require both quantitative (e.g., incident numbers) and qualitative (e.g., how incidents were uncovered, remediation steps) metrics for each step.
Standardise definitions and categories to enable comparability across companies and countries.

2

Forced labour must be explicitly prioritised in mHRDD laws

To address both the invisibility of forced labour and the vagueness of incident disclosures, mHRDD laws must set clearer and stronger requirements, such as:

Mandate explicit reporting on forms of modern slavery such as forced labour, with clear definitions of reportable issues.
Require detailed disclosures on incidents, including nature, location, scale, and outcomes for affected workers.
Provide tailored guidance for high-risk sectors and geographies where forced labour is prevalent.
Introduce standardised categorisation systems, such as the ILO’s Indicators of Forced Labour, to ensure comparability across companies.

3

Worker voice and remediation remain critical weaknesses in mHRDD laws assessed

Legislation should centre worker experiences to genuinely address and remedy violations:

Require clear disclosures of how grievance mechanisms are made accessible to supply chain workers.
Mandate transparency on their use, including the number and proportion of workers who utilise the grievance mechanism.
Require documented evidence of worker involvement in designing and implementing remediation.
Include measurable outcome metrics to demonstrate the effectiveness and impact of remediation actions.

4

Strong enforcement drives business compliance under mHRDD laws

Robust enforcement infrastructure is essential:

Establish well-resourced oversight bodies with mandates for rigorous enforcement.
Ensure explicit penalties are in place and applied effectively in practice.
Provide detailed guidance and standardised reporting templates outlining minimum standards.
Consider civil liability provisions to further strengthen corporate accountability.

Conclusion

The implementation of mHRDD laws is a step forward in advancing corporate accountability and worker protections, but their effectiveness hinges on the way they are designed and enforced. None of the laws assessed in Norway, Germany, or France were without issues in design or enforcement, although they represent the best human rights due diligence laws in force to date. This analysis highlighted that across all three mHRDD laws, detailed and explicit legal obligations drove stronger disclosures, forced labour can be forgotten if not specifically prioritised, vague reporting requirements limit access to credible information about how exploitation is identified and addressed, and that worker engagement, remediation, and enforcement are essential to deliver meaningful outcomes.

Policy makers should ensure that future mHRDD laws are clear, specific, and have strong enforcement mechanisms to better address forced labour concerns in supply chains. Embedding these principles into future legislation will ensure that corporate due diligence goes beyond compliance to deliver meaningful protection for people most at risk of exploitation.

All data can be accessed on wikirate.org.

Figure 1. Statements compared in this analysis.

Endnotes

[i]

Government of Norway (2022) The Transparency Act: Act relating to enterprises’ transparency and work on fundamental human rights and decent working conditions (Transparency Act). Oslo: Ministry of Children and Families. Available at: https://lovdata.no/dokument/NLE/lov/2021-06-18-99/%C2%A71#%C2%A71 (Accessed: 18 September 2025).

[ii]

Assemblée Nationale (2017) Loi n° 2017-399 du 27 mars 2017 relative au devoir de vigilance des sociétés mères et des entreprises donneuses d’ordre [Law on the duty of vigilance of parent and ordering companies]. Journal Officiel de la République Française, 28 March. Available at: https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000034290626/ (Accessed: 18 September 2025).

[iii]

Bundesministerium für Arbeit und Soziales (2021) Gesetz über die unternehmerischen Sorgfaltspflichten in Lieferketten (Lieferkettensorgfaltspflichtengesetz – LkSG) [Act on Corporate Due Diligence Obligations in Supply Chains]. Berlin: BMAS. Available at: https://www.bgbl.de/xaver/bgbl/start.xav?startbk=Bundesanzeiger_BGBl&jumpTo=bgbl121s2959.pdf#/text/bgbl121s2959.pdf?_ts=1758211269905 (Accessed: 18 September 2025).