In McKinsey’s 2026 State of AI survey, nearly nine in ten respondents said their organisation regularly uses AI in at least one business function. Suppliers are no different. When a supplier gets dozens of self-assessment questionnaires (SAQ), an AI tool can now write full, well phrased answers in minutes and draft policies and processes to accompany them. If your human rights due diligence relies on SAQs, those answers and documents are now worth much less.
SAQs already had their limits
SAQs have been useful. They reach a wide supplier base at low cost and give a first overview of policies and practices. But they were never strong evidence. The answers are self-reported, and often filled in by someone in Sales or Quality, far from the factory floor. They rarely reveal the issues that matter most to workers, such as recruitment fees, excessive overtime or undeclared subcontracting.
AI removes what was left
When I was developing supplier due diligence processes in 2015 in preparation for the reporting section under the UK Modern Slavery Act, SAQs were already a blunt tool. But the answers still told me something. Reading them, I could usually tell whether a supplier understood what I was asking about, or was just trying to tick the box. Today I can’t even get that first indication.
With an AI tool, every answer can look complete, confident and in line with what the buyer wants to read. And it goes one step further. When we ask for evidence, such as a code of conduct, a recruitment policy or a grievance procedure, AI can write those documents too, within minutes. A supplier can send back a full set of well-written policies that have never been used in practice.
Not every supplier uses AI this way, and AI can also help a supplier who means well to answer more fully. The problem is that a buyer can no longer tell which is which from the answers or documents alone.
What it means for workers and for your company
For workers, the risk is that real problems stay hidden behind well-written answers. For your company, it can give a false sense of assurance. The CSDDD asks companies to identify and address actual and potential adverse impacts, focusing on where they are most likely and severe. Under the EU Forced Labour Regulation (EU FLR), which applies from December 2027, products made with forced labour can be banned from the EU market. A folder of polished SAQ answers is unlikely to be strong evidence that you have looked properly, and risks leaving severe impacts unidentified.
From wide to deep
We think the era of SAQs as one of the main due diligence tools is coming to an end. That does not mean doing less, but instead asking smarter questions and looking more closely where it matters:
→ Start with risk data. Use country, sector and commodity risk data to find the suppliers where the risk of severe impacts is highest. AI can be a real help here, and we can support you in setting this up.
→ Ask fewer, factual questions. Avoid questions that invite the “right” answer, such as “how do you work to mitigate forced labour?”. Ask for facts instead. We recently supported a client who replaced a long questionnaire with a few core questions, such as whether suppliers employ migrant workers. Combined with supplier locations, the answers gave a clear picture of where to focus the next steps of their due diligence. This saved time for the suppliers and our client, whilst delivering a good result.
→ Use the SAQ for facts you can check. Sites, workforce size, use of migrant workers and labour agencies. Treat policies as a starting point, not as proof.
One thing to do next week
Map your country, sector and business relationship risks onto your supply base. This shows you where it’s most pressing to dig deeper and where you need answers. Focus your questions there, and let the answers guide your next steps.
Want to rethink how you assess suppliers? Get in touch!
Karin Iseman
Karin is a Senior Advisor at Enact with more than ten years of experience in supply chain risk management, labour rights and human rights due diligence. She supports organisations across a range of sectors in developing responsible sourcing strategies and addressing human rights risks throughout complex global supply chains.