What is expected of companies?

Belgium has committed to upholding the international human rights agreements mentioned above, including the duty to ensure these rights are respected in practice, notably through domestic laws, state institutions, and cooperation with other states.

For companies operating in Belgium, many of these international commitments are already reflected in national legislation. The Belgian Constitution (Official English Translation, 2021) guarantees a broad range of fundamental rights and prohibits discrimination. In addition, Belgium has enacted comprehensive laws and regulations covering labour rights, occupational health and safety, equality and non-discrimination, environmental protection, and consumer rights. These frameworks provide the legal foundation for corporate responsibility and accountability in domestic business operations.

Belgian National Action Plan on Business and Human Rights

In line with the UNGPs, Belgium adopted its first National Action Plan (NAP) on Business and Human Rights in 2017. The NAP outlined measures to promote responsible business conduct, improve access to remedy, and strengthen policy coherence across government departments. It also led to the creation of resources aimed at helping companies and organisations understand and embed human rights in their practices, which include:

• This Human Rights Toolbox, offering user-friendly tools to support businesses and their stakeholders in implementing human rights responsibilities;
• A Brochure on Access to Remedies in Belgium, summarising the main legal and non-legal remedies available to victims of human rights violations.

In 2024, Belgium published its second National Action Plan, which will run until 2029. This updated NAP builds on lessons from the first, and places greater emphasis on integrating human rights due diligence into corporate practice, supporting SMEs, and aligning with EU and international developments such as the CSDDD. It also outlines measures to improve policy coordination, stakeholder engagement, and access to remedy.

Legislative Developments

Belgium has also taken steps toward strengthening its legal framework. In April 2021, a legislative proposal was introduced to establish a mandatory human rights due diligence obligation for companies operating in Belgium. Although this proposal was not adopted — pending the finalisation of the CSDDD at the EU level — it signalled strong momentum toward aligning national practice with international standards and enhancing corporate accountability.

As an EU Member State, Belgium is now required to transpose the CSDDD into national law by July 2027. This will introduce legally binding due diligence obligations for Belgian companies. Businesses subject to the Directive will be expected to review and adapt their policies, processes, and governance structures accordingly. Further national guidance and implementation measures are anticipated to help companies comply with their duties in practice.

• The agricultural sector accounts for over half of child labor worldwide. Hazardous child labour is widespread. For instance, children may be exposed to toxic pesticides or dangerous machinery at very young ages. Most—but not all—child labour is linked with small-scale family farms.
• Forced labour risks are also widespread in the agricultural sector. Forced labour often takes the form of debt bondage (workers bound to employers through debt relations), but in some contexts (e.g. Uzbekistan and China) reports also indicate the existence of state-imposed forced labour.
• Alongside mining and construction, the ILO identifies agriculture as one the sectors with the highest health and safety risks. Key occupational health and safety risks include long working hours, extreme weather conditions, the use of hazardous chemicals and dangerous equipment, and musculoskeletal disorders.
• Discrimination is also a pervasive problem, with vulnerable groups such as migrant workers and female workers over-represented in some of the most dangerous and least rewarding activities such as harvesting or packing.
• Adequate wages are another area of concern, even more so than in other economic sectors. Many workers earn less than a living wage, particularly in contexts involving seasonal or casual labour. Wage exploitation is especially acute for migrant workers. In some supply chains, buyers' purchasing practices—such as last-minute orders or price pressures—contribute to further downward pressures on smallholder incomes and wages.
• Compounding these challenges is the fact that agriculture and fishing are among the sectors with the highest levels of informality. This means that agricultural workers often remain excluded from formal labor protections, social security benefits and formal representation e.g. through trade unions. Family members of smallholder farmers are a specific vulnerable group of informal workers, often facing financial hardship, physical strain, and limited opportunities for advancement, particularly for women and youth.
• In addition to worker rights, agricultural activities can also have adverse effects on the living environment of surrounding communities (including but not limited to indigenous communities) due to, for instance, declining water availability or soil pollution due to the use of pesticides.

• Child labour risks are concentrated in the artisanal and small-scale mining (ASM), which refers to low-tech, labour-intensive mining of minerals like gold, tin, tantalum, tungsten and cobalt. Work performed by children may be highly hazardous, and may involve exposure to toxic chemicals.
• Forced labour can occur in the form of debt bondage and abusive recruitment, again mostly in ASM.
• Occupational health and safety risks are among the highest of any sector. Key hazards include pit collapses, dust exposure, noise and vibration, lifting of heavy equipment, and exposure to toxic substances such as mercury and cyanide.
• Vulnerable groups such as women and migrant workers may face discrimination, being concentrated in the lowest-paid and most insecure activities (e.g. processing or carrying ores).
• Earnings in ASM are volatile, and often fall below living income. Subcontracting in large-scale mining can also introduce wage gaps with contracted workers.
• Risks for workers are compounded by the fact that a lot of ASM activities in particular are informal, with workers lacking access to even basic social protection.
• Communities in the vicinity of both artisanal and large-scale industrial mines may suffer important adverse impacts on their living environment, including security impacts, and the impacts of environmental disasters such as tailings dam failures. Mining may also lead to (forced) displacement of local communities, and can lead to social unrest, particularly in areas already affected by conflict or fragility.
• Of particular concern for the mining sector are attacks on human rights defenders.

• Child labour is concentrated upstream in cotton farming (see section "Agriculture") but also persist in informal subcontracting and home-based work in apparel production.
• Forced labour is prevalent in both raw material production and garment manufacturing. Particular concerns have been raised in relation to state-imposed or state-enabled forced labour in parts of the cotton/textile chain (notably but not exclusively in Xinjiang, China).
• Wages & purchasing practices: the textiles sector shows persistent gaps to living wages. At least in part, these gaps are due to price pressures on the part of buyers.
• Discrimination and gender-based violence & harassment are widespread, as women form a large share of apparel workers. In addition, textile hubs often rely on migrant workers, who are particularly at risk from exploitative recruitment and employment practices.
• Occupational health & safety concerns are also widespread. In apparel and textiles factories, workers may face long working hours, heat, noise and dust exposure (notably cotton dust exposure is well-documented). In addition, workers across the textiles value chain may be exposed to toxic chemicals (e.g. dyes, solvents, resins) that may harm workers' health if not adequately managed.
• Risks for workers are compounded by widespread informality, and a lack of effective worker representation. Textile supply chains (notably in apparel) often have hidden sub-contracting arrangements that involve casual contracts and home work.
• Fiber production and textiles manufacturing can have adverse impacts on local communities, e.g. by limiting the availability of clean water (water use and pollution), or through the use of toxic chemicals (e.g. pesticides).
• End of life: Textiles are among the most landfilled or incinerated consumer products. Inadequate waste management, especially in importing countries for used clothing, creates environmental burdens that affect local communities. Informal waste workers—often women and children—face unsafe conditions when handling textile waste without protective equipment.

• The construction sector is one of the largest recipients of forced labour globally. Migrant workers are particularly at risk, often recruited through abusive practices such as debt bondage, excessive recruitment fees, or passport confiscation.
• Construction is among the most dangerous sectors in terms of workplace accidents and fatalities. Common risks include falls from height, injuries from heavy machinery, exposure to dust, chemicals (such as asbestos), noise and vibration, and long working hours in extreme weather conditions.
• Construction frequently involves informal or temporary work arrangements. Multi-layered subcontracting chains are commonplace, creating a lack of transparency and accountability. Informal employment is widespread, leaving workers vulnerable to exploitation and depriving them of access to social and legal protection.
• Wage withholding and delayed or unpaid wages are widely reported issues, particularly for migrant and subcontracted workers.
• Within the EU, concerns around social dumping have been prominent in the construction sector. This refers to situations where workers from lower-wage Member States (or third countries) are posted to higher-wage countries under inferior working conditions, often through complex subcontracting arrangements.
• Large construction projects can have significant impacts on surrounding communities, including (forced or voluntary) displacement and environmental impacts such as dust, noise, and water pollution. In some contexts, construction projects have also been linked to corruption and adverse impacts on local governance.

• Gross human rights abuses: Companies may become linked, either directly or through business partners, to serious abuses such as killings, torture, forced displacement, or sexual and gender-based violence
• Conflict financing: Revenues from natural resources, trade, or taxation may end up funding armed groups. This risk is especially acute in relation to certain minerals (e.g. gold, 3TG, cobalt) but may extend to other sectors.
• Security forces: In conflict contexts, the public or private security providers that companies rely on may themselves be responsible for human rights abuses.
• Weak governance: In many CAHRAs, the state is unwilling or unable to protect human rights, which creates additional responsibility for companies.
• Community impacts: Business activities in conflict settings may exacerbate social tensions by reinforcing inequalities between groups.

Given the acute nature of human rights risks in CAHRAs, companies operating in- or sourcing from these regions also face tougher expectations. The UNGPs and the OECD Due Diligence Guidance explicitly call on companies to apply "heightened" due diligence when operating in CAHRAs. Among other things, this includes more frequent and in-depth risk assessments of impacts and risks, adopting conflict-sensitive approaches to stakeholder engagement, and ensuring responsible security practices.