Solving the Transparency Gap as CSDDD and EU Forced Labor Regulation Dates Loom

The convergence of the EU’s due diligence directive and forced labor regulation marks a pivot point for procurement teams: the shift to data-driven vigilance. The risk of non-compliance is no longer just a legal issue, too – it is a direct threat to the flow of goods. To stay ahead, procurement must solve the persistent challenge of the “transparency gap.”

As we approach 2027, the regulatory landscape is shifting from voluntary reporting to mandatory operational requirements. The EU Forced Labour Regulation (EUFLR) will soon prohibit the import, sale, and export of any goods linked to forced labor, regardless of where they were produced. Simultaneously, the Corporate Sustainability Due Diligence Directive (CSDDD) is forcing companies to examine their “chain of activities” more deeply than ever before.

Complexity vs. Clarity

The introduction of these directives is a game-changer – the CSDDD and EUFLR demand a “zero tolerance” approach to human rights violations. Even with recent moves to streamline reporting requirements – such as the Omnibus Simplification Package – the core obligation remains: companies must effectively identify and mitigate risks, even deep within complex global supply chains. While the simplification measures are designed to reduce the administrative burden of reporting, they are not to lower the standard of human rights protection by effectively sharpening the regulator’s focus on the actual effectiveness of your due diligence.

Those without visibility not only fall short of regulatory expectations but also expose organizations to delays, cost increases, and production disruptions.

Why Audits Are Not Enough 

The greatest pain point for sustainable procurement today is visibility. Most professionals rely on conventional supplier audits to gauge compliance. While valuable, these audits provide only “snapshots” in time. They are often scheduled in advance and can miss systemic labor violations that occur deep in the supply chain or outside the audit window.

This lack of continuous visibility creates a transparency gap. Even the US Customs and Border Protection (CBP) has warned that “no single audit can serve as a definitive assessment” of forced labor risks. Relying solely on these static reports leaves procurement teams blind to the daily realities of the workers making their products.

The Cost of Running Blind

The consequences of this visibility gap are already playing out in global markets. The US serves as a preview of what European companies can expect once the EUFLR is fully active. Since 2022, more than 48,000 shipments worth USD 3.9 billion have been detained under the Uyghur Forced Labor Prevention Act (UFLPA). The pace of enforcement is accelerating, with almost as many shipments detained in 2025 as in 2023 and 2024 combined.

In Europe, the German Supply Chain Due Diligence Act (LkSG) has shown similar teeth. In its first year alone, 206 complaints were filed, leading to 58 formal investigations and nearly 500 inspections focused on high-risk sectors like textiles and electronics. These figures demonstrate that human rights violations are not distant theoretical risks but concrete operational threats that affect delivery capability and market access.

Closing the Gap with Worker Voice 

To secure supply continuity, procurement needs to move beyond static verification toward continuous monitoring. This is where tools like EcoVadis Worker Voice come in, offering a solution that closes the transparency gap. By providing a digital, anonymous grievance and feedback channel, companies can gain real-time visibility into their supply chain.

Unlike a periodic audit, this approach acts as a true early warning system. It empowers workers to report issues safely and allows suppliers to address problems transparently and without the fear of retaliation before they escalate into regulatory investigations, NGO campaigns, or reputational crises.

Resilience as a Competitive Edge 

Ultimately, proactive due diligence is simply good business. Identifying a risk early through a worker survey costs far less than managing a detained shipment or a public relations crisis later. Companies that act transparently not only avoid fines and production halts but also strengthen their position in tenders and improve their ESG ratings. In an era where regulatory and market pressures are rising simultaneously, listening to the workforce is no longer just a moral choice – it is a strategic necessity for safeguarding the supply chain.

Learn more about how Worker Voice strengthens your human rights due diligence and builds resilience.  Speak to an expert about our solutions.