Implementing Due Diligence for the EU Forced Labour Regulation and Beyond: Lessons from the New Guidance

By Claire Kaula

The EU Forced Labour Regulation (FLR) bans the sale, import, and export of any products made with forced labor across all sectors in the EU. It joins an increasing number of global regulations focused on forced labor, including modern slavery legislation in the United Kingdom, Australia, and Canada, the Uyghur Forced Labor Prevention Act (UFLPA) in the United States, and the proposed Modern Slavery Bill in New Zealand.

Companies need to prepare now to ensure they are confident that the products they sell, import, or export on the EU market are not made with forced labor starting on December 14, 2027. Due diligence is key for companies to identify and address forced labor risks to meet the FLR’s expectations. Rather than approaching forced labor due diligence as a standalone compliance exercise, companies have the opportunity to increase efficiency by building integrated due diligence systems that address forced labor and other human rights impacts together. Integrated due diligence systems can meet FLR expectations while also aligning with EU regulations such as the Corporate Sustainability Due Diligence Directive (CSDDD), the EU Batteries Regulation, and the EU Deforestation Regulation, and preparing for anticipated human rights due diligence legislation in Japan, Thailand, and other countries.

In this blog we will set out how companies can build a comprehensive due diligence approach for the FLR and beyond.

Implementing Due Diligence to Prepare for the EU Forced Labor Regulation 

The goal of the FLR is to eradicate forced labor in all forms and promote decent labor conditions globally by regulating the EU market. To do so, companies must identify, prevent, and address forced labor risks in their supply chains. While the FLR does not include specific due diligence requirements, it makes clear that due diligence is an effective strategy against forced labor. Furthermore, it will be advantageous for companies in scope for the FLR to demonstrate their due diligence efforts. For example, the FLR explicitly recognizes that due diligence can help companies demonstrate, should they be subject to an investigation, that products were not made with forced labor.

The European Commission’s official Guidance on the application of the FLR, released in June 2026, clarifies that to conduct due diligence for forced labor companies should:

• Follow the foundational OECD six-step due diligence framework. Companies should tailor this approach to their particular situation and not use it as a “tick box” exercise. It is important to note that the OECD-aligned identification criteria for the due diligence framework is independent from the Guidance on identifying products that should be subject to investigations under the FLR.
• Integrate forced labor due diligence into existing policies and risk management systems. Companies do not need to develop independent forced labor approaches but can instead leverage existing systems and work from multi-stakeholder initiatives and industry associations.
• Conduct meaningful engagement with stakeholders who could be impacted by forced labor from the company’s activities to identify and mitigate the risk. Direct engagement with workers should be confidential, ensure safety, and be accurate. Where this is not possible, companies can engage with credible experts, unions, civil society, and other credible information sources.
• Prevent, mitigate and bring to an end identified forced labor risks. Do so by taking appropriate measures like implementing corrective action plans, adapting business practices, cooperation with remediation mechanisms, or establishing complaint mechanisms.

The FLR Guidance is clear that companies can integrate forced labor due diligence into their broader, company-wide due diligence systems.

Building a Multi-functional FLR Due Diligence System 

The FLR’s Due Diligence Guidance, like other global due diligence regulatory requirements, are based on international principles and standards such as the UN Guiding Principles on Business and Human Rights (UNGPs) and OECD Guidelines for Multinational Enterprises. Given this overlap, companies can take advantage of this alignment and integrate FLR related due diligence into broader human rights due diligence systems.

To build a comprehensive due diligence system that meets FLR, consider beginning with the following activities:

• Map existing forced labor and human rights due diligence activities. This mapping could be integrated into a broader corporate-wide human rights impact assessment or other regulatory efforts. For example, when assessing CSDDD readiness or UNGP alignment for EU Taxonomy, build specific questions on forced labor to consider what existing practices and systems manage forced labor risks.
• Assess where bespoke forced labor due diligence activities are required. When identifying forced labor risks, consider if there are risks associated with any regions, products, or supply chain tiers that are linked to systemic or elevated forced labor risks. Where this is the case, conduct an in-depth assessment to assess whether the forced labor risks require a bespoke due diligence approach to ensure adequate prevention, mitigation, and ending of the risk.
• Collaborate with functions across the company to integrate forced labor due diligence across the company. Leverage existing due diligence programs across different teams such as procurement, sustainability, legal, and safety and privacy. This will help ensure due diligence systems for forced labor are not duplicative.

Conclusion 

The FLR presents the opportunity for companies to have a due diligence system that not only addresses forced labor but is also one that is functional across the evolving regulatory due diligence landscape. The result is a win-win: companies gain future-proof due diligence systems, and people’s human rights are better respected through more effective due diligence.

To learn more and explore how your company can develop due diligence systems that meet the EU Forced Labor Regulation while also preparing for other due diligence regulations, please reach out at hello@articleoneadvisors.com.