Key Compliance Requirements for Businesses
Companies must map supply chains, conduct regular risk assessments, maintain detailed documentation, and develop remediation plans well ahead of the 2027 enforcement deadline.
Transparency is a cornerstone of the regulation. Companies must map their supply chains and maintain detailed records of their suppliers, including information about the origin of raw materials, production processes, and the labor practices of each supplier. This mapping must extend beyond Tier 1 to sub-suppliers and components, covering the full lifecycle of a product from raw material extraction to finished goods.
Companies are required to conduct thorough due diligence on their supply chains — identifying and assessing the risks of forced labor at various stages of production and regularly updating those assessments to reflect changing circumstances. They must also establish mechanisms to constantly monitor suppliers and sub-suppliers, either through third-party systems or internal teams, ensuring compliance on an ongoing basis.
In cases where forced labor is identified, companies are required to take immediate action to rectify the situation. This includes developing and implementing remediation plans in collaboration with affected workers and relevant stakeholders, aimed at eliminating forced labor practices and providing support to impacted individuals. Companies must maintain comprehensive documentation of their due diligence efforts, risk assessments, audits, and remediation activities, and must be prepared to submit that documentation to regulatory authorities upon request.