What happened
On 9 September 2026, CGT-FAPT, the Data Labelers Association and The Oversight Lab, supported by the legal collective Intérêt à Agir and research network DIPLab, issued a formal notice to Teleperformance SE under the French Duty of Vigilance Law. The action was announced in Geneva, at the International Labour Organization, during a colloquium on labour in AI value chains organised by the International Network of Digital Labour.
The notice concerns workers employed across the TP Group in AI data annotation and content moderation for social media platforms, including in Kenya. It alleges that Teleperformance SE’s vigilance plan fails to adequately identify, assess and prevent several serious risks: migrant workers allegedly working without the required permits, delays or failures in remitting social security contributions deducted from wages, inadequate grievance mechanisms, and particularly demanding working conditions for content moderators. Several workers reportedly said their contracts were not renewed after they took part in collective initiatives.
The notice follows earlier investigations into the same workforce, including reporting by openDemocracy in June 2026 on migrant workers employed by Teleperformance in Nairobi, and a May 2025 report by labour rights organisation Equidem.
Why it matters beyond one company
Content moderation and data annotation sit several tiers into a value chain that most companies using AI systems never see directly. The people doing this work label and filter the content that trains and moderates the platforms and models businesses now rely on daily, yet their working conditions rarely feature in the due diligence processes of the companies at the top of that chain.
The organisations behind this notice are calling on Teleperformance SE to revise its vigilance plan, assess conditions on the ground with trade unions, and establish a genuinely accessible grievance mechanism. The company now has three months to respond before the matter can be brought before the Paris Judicial Court.
What this signals for due diligence practice
For businesses relying on outsourced content moderation or data annotation, whether directly or through platform partners, this case is a reminder that due diligence obligations extend to the people doing this often invisible work. A vigilance plan, or a due diligence process built to satisfy the CSDDD, only holds up if it reflects what is actually happening on the ground, not what looks adequate on paper, which this notice will now test.
Read the formal notice: TELEPERFORMANCE_Formal_Notice_September_2026.pdf
Teleperformance has previously responded to related allegations about the mental health impact of content moderation work on outsourced staff; that response is available via BHRC’s Company Response Mechanism.