"While the specifics vary, the global trend is apparent: governments are demanding greater transparency and accountability from businesses on their supply chain labor due diligence practices.” Kimberly Rodriguez, Consultant specializing in sustainable supply chains with BSI Consulting
Global expectations for responsible business are intensifying, and human rights compliance has entered a new era: one marked by stricter mandates, broader accountability, and growing pressure from regulators, investors, and stakeholders.
While the United Kingdom (UK) Modern Slavery Act marked a pivotal starting point, countries across the world are now advancing more prescriptive laws that demand deeper transparency and proactive due diligence efforts (read UK Modern Slavery Act 2015 and Its Global Influence). The expectations for how organizations assess risks, manage their supply chains, and demonstrate meaningful human rights protections have grown significantly, and the consequences of not doing so have become clearer.
As countries around the world are rolling out tougher human rights regulations, it can be hard to keep track of what’s changing. To help make sense of it all, here are some of the major regulations over the last few years that are reshaping what compliance looks like.
California Transparency in Supply Chains Act (2010) applies to retail sellers and manufacturers doing business in California with worldwide gross receipts exceeding $100 million. The Act requires disclosure of efforts across five specific areas but notably does not mandate implementation; companies can state that they take no action and remain compliant. Enforcement is limited to injunctive relief through the California Attorney General, with no direct financial penalties though the Act influenced subsequent legislation globally, including the UK Modern Slavery Act.
French Corporate Duty of Vigilance Law (2017) applies to large French companies with 5,000+ employees in France or 10,000+ employees globally. Companies must establish and publish an annual vigilance plan covering human rights, health and safety, and environmental risks across operations, subsidiaries, and suppliers. Courts can impose fines of up to €10 million for failure to publish plans and up to €30 million if this failure results in preventable damages. Notably, companies can be held civilly liable for damages when compliance would have prevented harm, creating genuine financial exposure beyond reputational consequences.
Australia's Modern Slavery Act 2018 applies to entities with annual consolidated revenue of AUD $100 million or more, requiring annual modern slavery statements through a central online register. Unlike the UK's discretionary approach, Australia mandates specific content covering seven criteria. Following a 2024 statutory review, the government plans to introduce mandatory due diligence requirements. While currently carrying no direct financial penalties, the appointment of an Australian Anti-Slavery Commissioner in 2024 signals a shift toward more robust enforcement.
Germany Supply Chain Due Diligence Act, operational since 2023, applies to companies with 1,000+ employees and is considered the most prescriptive globally. It requires risk analysis, management systems, immediate remedial action for violations, and annual reporting. Penalties reach €8 million or 2% of annual turnover plus potential exclusion from public procurement.
Norwegian Transparency Act (2022) goes further by requiring companies to respond to public information requests about specific suppliers within three weeks. Fines can reach up to 4% of annual turnover for serious violations.
Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act, effective 2024, requires annual reporting with attestation that reports are accurate. Noncompliance can result in fines of up to CAD $250,000.
The European Union (EU) Corporate Sustainability Due Diligence Directive (CSDDD) and EU Forced Labour Regulation represent the next evolution in compliance requirements. While both are currently subject to scope revisions through the EU's “Omnibus” simplification package, corporations with significant operations in the EU should continue to be proactive as the final legislation may introduce changes to scope, obligations, or enforcement.
The EU Forced Labour Regulation: A new enforcement mechanism
The EU Forced Labour Regulation entered into force on December 13, 2024, and will be fully applicable as of December 14, 2027. Unlike transparency-focused legislation, this regulation establishes an outright ban on products made with forced labor from being placed on the EU market or exported from the EU.
The EU Forced Labour Regulation's scope is comprehensive, applying to all products and components regardless of sector, origin, or whether they're domestically produced or imported. The regulation aligns its definition of “forced labor” with International Labour Organization conventions covering a wide variety of coercive labor practices.
Notably, while the EU regulation does not impose additional due diligence obligations beyond existing EU laws, it recognizes that any due diligence that has already been carried out will be taken into account during investigations, which could help organizations avoid investigations altogether. The European Commission will issue additional compliance guidelines by June 14, 2026.
Comparing approaches: Transparency versus import bans
When trying to make sense of all the new rules, it helps to start with the big picture. As of now, most countries are leaning toward one of two distinct approaches to tackling forced labor: increasing transparency or avoiding import bans. Both approaches share the same goal of moving the needle on forced labor risk, pushing companies to take action and responsibility throughout their supply chains.
- Transparency and due diligence laws (UK, Australia, Norway, Germany, France, Canada) require companies to disclose continuous efforts and implement management systems, with penalties for noncompliance ranging from reputational damage to significant fines.
- Import bans (US Uyghur Forced Labor Prevention Act, EU Forced Labour Regulation) prohibit products made with forced labor from entering markets. These regulations focus on enforcement through customs authorities and supply chain investigations rather than corporate disclosure.
Organizations operating globally must prepare for both approaches as each one tackles a different part of the evolving forced labor landscape.
Today’s impact
Modern slavery regulations are quickly changing from basic transparency requirements to mandatory, enforceable due diligence laws, many with increasingly enforceable penalties as a consequence of noncompliance. Organizations can no longer rely on disclosures alone but must demonstrate active, effective risk management throughout their supply chains.
Compliance team tips:
- The UK Modern Slavery Act remains relevant: Despite calls for reform, it continues to apply to thousands of companies globally and serves as a foundation for understanding modern slavery compliance.
- Enforcement is intensifying: New regulations feature substantial financial penalties and import restrictions, raising the stakes beyond reputational risk.
- Due diligence must be risk based and comprehensive: Modern legislation requires systematic identification, assessment, and mitigation of forced labor risks throughout value chains.
- Cross-border complexity is increasing: Organizations must navigate multiple overlapping frameworks, each with different thresholds, requirements, and enforcement mechanisms.
Despite the constantly changing nature of forced labor regulations, what remains true is that at the heart of all these efforts is the acknowledgement of ensuring the dignity and proper treatment of the people who make global businesses possible. Understanding regulatory requirements is just the first step; it is the thoughtful implementation of these requirements where true impact can be made.
Follow our modern slavery blog series, where we break down human rights compliance regulations across different jurisdictions and what they mean for your due diligence obligations.
Blog 2: UK Modern Slavery Act 2015 and Its Global Influence
Blog 1: What Modern Slavery Means for Today’s Supply Chains
BSI Consulting's e-book: From policy to practice: Eradicating modern slavery, Fighting worker exploitation throughout global supply chains.
