The summer slowdown is more perception than reality. Business activity may be quieter, but regulatory deadlines still arrive, legal cases keep moving, and the people most exposed to business-related harm are not on holiday.
This year, that reality comes with a sharper edge. OECD’s latest Responsible Business Outlook 2026, published in June, found that only 8% of large, listed companies report engaging stakeholders on human rights issues. Just 17% have a formal grievance mechanism. And only 10% commit to providing remedy to people affected by human rights impacts connected to their activities.
These are the world’s largest listed companies, operating under internationally recognised frameworks that have existed for over a decade. Yet the gap between what due diligence is supposed to look like and what is actually happening remains, by any honest assessment, vast. That is the backdrop against which we are following ten topics this summer. These are not predictions. They are areas where we see continued movement, increasing relevance, or persistent gaps that deserve attention as we head into autumn.
1. CSDDD implementation: the gap between ambition and guidance
The consultation on the European Commission’s implementation guidelines for CSDDD runs until 24 July 2026, with formal adoption planned for early 2027. The stakes are high, not because the directive is new, but because the guidance will determine whether it produces genuine change or a new generation of compliance theatre.
The questions that matter most are the ones the OECD data surfaces: how will the guidelines address stakeholder engagement in practice? What will meaningful remediation actually require? These are precisely the areas where companies are furthest behind.
2. EU Forced Labour Regulation: traceability as a human question
The EU Forced Labour Regulation is moving from principle to practice. For companies sourcing across global value chains, the questions becoming more pressing are concrete: how do you demonstrate traceability? What does genuine supplier engagement look like? Who in the supply chain cannot speak freely, and why?
The regulation will ultimately be tested against real situations involving real workers. That is the lens we think companies should apply to their own preparedness.
3. AI in due diligence: a useful tool that can also conceal
Artificial intelligence is increasingly being used for risk screening and research in due diligence processes. Used well, it can expand reach and improve consistency. Used poorly, it can generate a false sense of completeness – processing large volumes of data while missing what matters most: the experiences and voices of the people affected.
As the Business and Human Rights Resource Centre has documented extensively, AI raises its own human rights risks, including privacy, discrimination and the erosion of democratic safeguards. Companies adopting AI in their due diligence should also ask who is being listened to less as a result.
4. Migrant workers: heightened risk, limited visibility
Migrant workers remain among the most exposed people in global value chains. Recruitment fees, debt, subcontracting, restricted freedom of movement, limited access to remedy – these are not edge cases. They are structural features of the way labour is organised across many sectors and corridors.
This is an area we will continue to follow closely, including through our ongoing webinar series on migrant workers in global value chains. For companies, the question is not only whether risks exist, but whether their systems are designed in a way that makes those risks visible to them at all.
5. Shrinking civic space: losing the eyes and ears of due diligence
Meaningful due diligence depends on independent information: worker testimony, civil society reporting, investigative research. As civic space narrows, through funding cuts, legal restrictions and political pressure, companies are losing access to the sources that make their assessments credible.
This is not only a human rights problem. It is a practical problem for any company trying to understand what is actually happening in its operations and supply chain. If the organisations that document and report abuse cannot function, the quality of corporate due diligence degrades with them.
6. Climate, natural resources and accountability
The connection between climate ambition and human rights impact is no longer theoretical. Sourcing decisions for transition minerals, land-use choices, the pace of energy transition in communities dependent on extractive industries – these carry consequences for specific people in specific places.
The just transition debate is increasingly concrete: who benefits, who bears the costs, and who gets to participate in decisions that will shape their futures.
7. Public procurement: the quiet driver of due diligence
Procurement requirements are a significant lever for responsible business conduct. Requirements around risk analysis, supplier follow-up and corrective action are appearing with increasing frequency in public contracts, not only in voluntary frameworks.
For companies that supply public sector organisations, this changes the landscape. Compliance is no longer something you can defer to a voluntary timeline.
8. Simplified ESRS and VSME: what simplification actually means
The European Commission’s proposals for simplified ESRS reporting standards and a revised VSME have completed their consultation phase. The direction of travel – fewer requirements, lighter obligations for smaller companies – reflects real concerns about burden. But simplification always involves choices about what gets left out.
We will be following the adoption process carefully, and in particular what the revised standards mean for value chain information requests and the visibility of impacts upstream from large companies.
9. Litigation: the cases that show where systems fail
Recent court cases – from the Lafarge terrorism financing conviction in France to a series of supply chain liability cases across Europe – continue to demonstrate that due diligence is being scrutinised in practice, not only in theory.
These cases matter for legal risk. But they matter more because they consistently centre on workers and communities whose experiences reveal where company systems have failed to prevent or address harm. The cases do not simply illustrate legal risk. They tell us something about what good practice would have needed to look like.
10. Business and human rights beyond Europe
EU developments attract most of the attention. But responsible business expectations are evolving through national legislation in multiple markets, through international standard-setting under the UNGPs and OECD Guidelines, through investor scrutiny, and through litigation in jurisdictions outside Europe. For companies operating across markets, the European regulatory agenda is the floor, not the full picture.
What connects these ten topics is something the OECD data makes hard to ignore: the gap between stated commitments and actual practice remains wide, particularly when it comes to listening to people and providing remedy when things go wrong.
That gap is not mainly a problem of knowledge or intention. It is a problem of design. Companies that are serious about closing it will need to build systems that are genuinely capable of hearing what is happening, and of responding to it.
We will continue following these developments over the summer and we will return with more detailed reflections on several of these themes. If any of them are live questions in your organisation right now, we are happy to talk!