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Human Rights Due Diligence (HRDD) under the CSDDD

Last updated · 2026-06-08

Human rights due diligence (HRDD) is the ongoing process a company uses to identify, prevent, mitigate and account for how its operations and business relationships affect people. It comes from the UN Guiding Principles and the OECD Guidelines, and the EU Corporate Sustainability Due Diligence Directive (CSDDD) now makes this process a legal obligation for the largest companies, alongside environmental due diligence.

TL;DR

  • HRDD is a risk-based process to find and address adverse human rights impacts your company causes, contributes to, or is linked to through its chain of activities.
  • It originates in the UN Guiding Principles on Business and Human Rights (2011) and the OECD Guidelines / Due Diligence Guidance.
  • The CSDDD (Directive (EU) 2024/1760), as amended by Omnibus I (Directive (EU) 2026/470), turns HRDD plus environmental due diligence into a binding duty for large in-scope companies.
  • It follows a six-step cycle: embed, assess, prevent and mitigate, remediate, engage and complaints, monitor and communicate.
  • Even if your company is too small to be directly in scope, customers in scope will push HRDD expectations onto you as a supplier.
Free DD QuestionnaireCheck if you are in scope

In plain English

What human rights due diligence means

Human rights due diligence is not a one-off audit or a signed pledge. It is a continuous management process: you look at where your business could harm people (workers, communities, consumers), prioritise the most severe and likely risks, take action to prevent or reduce them, fix harms you caused or contributed to, give affected people a way to raise concerns, and track whether your measures are working. The same logic the OECD applies to environmental and governance impacts applies to human rights, which is why the CSDDD treats them together as one due diligence obligation.

How this fits the CSDDD

HRDD is the human-rights dimension of the full CSDDD six-step due diligence cycle, embedded under step 1 and assessed under step 2 of Directive (EU) 2024/1760. Directive (EU) 2024/1760 Omnibus I (Directive (EU) 2026/470)

Why it matters

Why human rights due diligence matters under the CSDDD

  • It is the human-rights half of the CSDDD due diligence duty. In-scope companies must do it across their own operations, their subsidiaries and their chain of activities.
  • Supervisory authorities in each Member State can investigate and fine companies that fail to carry it out, with penalties capped at no more than 3% of net worldwide turnover.
  • Large customers operationalise HRDD by sending due diligence questionnaires and codes of conduct down to suppliers, so smaller firms feel it indirectly.
  • Done well, it reduces legal, operational and reputational risk and builds more resilient, transparent supply relationships.

The detail

Where HRDD comes from: UNGPs and the OECD

The concept was set out in the UN Guiding Principles on Business and Human Rights, endorsed by the UN in 2011. They establish the corporate "responsibility to respect" human rights and describe due diligence as the way companies meet it.

The OECD Guidelines for Multinational Enterprises and the OECD Due Diligence Guidance for Responsible Business Conduct translate that responsibility into a practical, repeatable six-step process. The CSDDD deliberately mirrors this framework so that companies already following the OECD approach are largely on the right track.

How the CSDDD operationalises HRDD

The CSDDD requires in-scope companies to embed due diligence into their policies, identify and assess actual and potential adverse impacts, prevent or mitigate them, bring actual impacts to an end and remediate, run a complaints mechanism and stakeholder engagement, and monitor and communicate on effectiveness.

Omnibus I (Directive (EU) 2026/470) kept this structure but made the assessment risk-based and focused on direct (tier-1) business partners, with deeper investigation triggered only by plausible information of an impact further down the chain. Effectiveness assessments moved from every 12 months to at least every five years.

Salient human rights issues to look for

A "salient issue" is a human rights risk that is most severe and most likely in your specific operations and supply chain. Typical salient issues include forced labour and modern slavery, child labour, unsafe working conditions, excessive working hours and underpayment, discrimination, freedom of association, land rights and impacts on local communities, and the rights of vulnerable or migrant workers.

You identify salient issues by combining country risk, sector risk and product or commodity risk, then prioritise the most serious. This prioritisation is explicitly allowed under both the OECD framework and the CSDDD.

For the underlying standards, see the OECD Due Diligence Guidance and the UN Guiding Principles on Business and Human Rights.

Step by step

How to approach human rights due diligence

  1. Embed a human rights commitment into your policies and a code of conduct for staff, subsidiaries and business partners.
  2. Identify and assess actual and potential human rights impacts using a risk-based scoping exercise (country x sector x product).
  3. Prevent and mitigate potential impacts through action plans, contractual assurances and supplier support.
  4. Bring actual impacts to an end and provide or cooperate in remediation for those harmed.
  5. Run a complaints and notification mechanism and engage meaningfully with affected stakeholders.
  6. Monitor the effectiveness of your measures and communicate publicly on your due diligence.

Watch out

Common pitfalls

  • Treating a signed supplier declaration as evidence of compliance, without any verification.
  • Mapping everything equally instead of prioritising the most severe and likely (salient) risks.
  • Stopping at tier-1 even when you hold plausible information of a serious impact deeper in the chain.
  • Cutting and running from a supplier when suspending and supporting an action plan would better protect affected people.

Put it into practice

Ready to act on this? Start with our free due diligence questionnaire to see what a customer can ask you for, check whether you are directly in scope with the scope checker, score your suppliers with the risk-assessment tool, and look up any unfamiliar term in the glossary. For the full picture of the directive, read what the CSDDD is.

FAQ

Human Rights Due Diligence: common questions

What is human rights due diligence in simple terms?
It is an ongoing process a company uses to find out how it might harm people through its own activities and its business relationships, then prevent or reduce that harm, fix what it caused, and report on it. It is risk-based, so you focus first on the most severe and likely impacts.
Is human rights due diligence mandatory under the CSDDD?
Yes, for companies that meet the thresholds. Under the CSDDD as amended by Omnibus I, EU companies with more than 5,000 employees and more than 1.5 billion euros in worldwide net turnover, and non-EU companies with more than 1.5 billion euros of EU net turnover, must carry out human rights and environmental due diligence. Smaller firms are affected indirectly as suppliers.
What is the difference between HRDD and the UN Guiding Principles?
The UN Guiding Principles set out the expectation that companies respect human rights and describe due diligence as the way to do it. HRDD is that due diligence in practice. The CSDDD takes the same idea and makes it a legal requirement for large companies in the EU market.
What are salient human rights issues?
They are the human rights risks that are most severe and most likely in your particular business and supply chain, for example forced labour, child labour, unsafe conditions or discrimination. Identifying them lets you prioritise where to act first, which both the OECD framework and the CSDDD allow.

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Supply Chain Risk Assessment

A supply chain risk assessment, also called a human rights risk assessment, is how you score where adverse human rights and environmental impacts are most likely and most severe across your chain of activities. Under the EU Corporate Sustainability Due Diligence Directive (CSDDD), this assessment drives where you prioritise prevention, verification and remediation.

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Get ahead of the CSDDD

If a big customer has sent you a due diligence questionnaire, our free DDQ shows what you actually need to send. Then explore the tools and guides built for your role.

Free DD Questionnaire

This is guidance, not legal advice

This page explains how human rights due diligence works under the CSDDD in plain English. It is guidance, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser. The directive is still settling after Omnibus I, so we keep this page current.

Sources

  1. [1]Directive (EU) 2024/1760 (CSDDD / CS3D), original text (EUR-Lex)retrieved 8 Jun 2026
  2. [2]Omnibus I final amending act (Directive (EU) 2026/470): CSDDD amendments finalisedretrieved 8 Jun 2026
  3. [3]Clifford Chance: Omnibus I concludes CSDDD and CSRD reformsretrieved 8 Jun 2026
  4. [4]European Commission: Corporate sustainability due diligenceretrieved 8 Jun 2026
  5. [5]OECD Due Diligence Guidance for Responsible Business Conductretrieved 8 Jun 2026
  6. [6]UN Guiding Principles on Business and Human Rightsretrieved 8 Jun 2026

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