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What is expected of companies?

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International, regional and national regulatory landscape Company scope and obligations States engaging with private organisations High-risk sectors and areas

International, regional and national regulatory landscape

Intro International framework European (regional) frameworks National frameworks
This section helps you navigate the regulatory landscape defining corporate responsibilities in relation to human rights—at the international, regional, and domestic levels.

Companies are expected to respect human rights. This is core to responsible business conduct and represents the baseline expectation for every company, regardless of its size or sector. It means avoiding causing harm to people's rights and taking action to address any negative impacts they may be involved in.

1

International framework

2

European (regional) frameworks

3

National frameworks

What are human rights?

Human rights are rights that belong to every person simply because they are human. At their core, they are about treating all people with dignity. They apply everywhere, to everyone – regardless of race, gender, nationality, ethnicity, religion, language, or any other status — and they must be enjoyed without discrimination.

Human rights are recognized and protected in international law, mainly through treaties and conventions. While states have a duty to respect, protect, and fulfil these rights, companies are also expected to respect them, not only in their own activities but also through their business relationships.

The corporate responsibility to respect human rights is grounded in a growing body of international, regional, and national frameworks.

International Framework

International Framework International binding and non-binding Human Rights law, standards, and principles

The global standard for what is expected of companies with regards to human rights rests on two key international instruments:

the United Nations Guiding Principles on
Business and Human Rights (UNGPs)
the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines).

These are “soft law” instruments – they do not create legally binding obligations - nonetheless they are internationally recognized guidelines and have gained significant support as governments, companies, civil society organizations, European institutions and many other actors around the world have endorsed the principles and committed to put them into practice.
Importantly, the UNGPs and the OECD Guidelines have also paved the way for national and EU-level policies that are transforming HREDD expectations into a legal requirement (see sections on regional and national frameworks).

The United Nations Guiding Principles on Business and Human Rights

The UNGPs were developed under the leadership of Professor John Ruggie and his team, following years of multi-stakeholder consultations, and were unanimously endorsed by the UN Human Rights Council in June 2011. They are built on three pillars that outline the complementary - but distinct - roles of States and companies in relation to human rights:

Pillar 1: The State duty to protect
States have an obligation under international human rights law to protect individuals within their territory or under their jurisdiction from human rights abuses, including those linked to business activities. They do this through policies, laws, regulations and enforcement.
Pillar 2: The corporate responsibility to respect
Companies must take proactive steps to avoid harming people’s rights, both in their own operations and through their business relationships.
Pillar 3: Access to remedy
both States and companies must ensure that people whose rights have been harmed can obtain effective remedy.

The UNGPs provide companies with a practical framework for companies to meet this responsibility through policies and processes appropriate to their size and circumstances, including:

1

A public commitment to respect human rights.

2

A human rights due diligence process to identify, prevent, mitigate, and account for how they address their impacts on human rights.

3

Processes to provide or cooperate in remediation where they cause or contribute to adverse impacts

Like conventional due diligence in business or law, human rights due diligence (HRDD) is about managing risk. The key difference is that while traditional due diligence focuses mainly on risks to the company (e.g. financial, legal, reputational), HRDD focuses on risks to people. This shift in perspective is what makes HRDD distinctive.

Importantly, HRDD also represents a standard of conduct; it sets out how a reasonable company is expected to behave under the given circumstances. In other words, companies are not assessed by whether all risks are eliminated, but by whether they can demonstrate that they have taken the appropriate steps - proportionate to their size, activities, and risk profile - to identify, prevent, and address human rights impacts. It is the appropriateness of the steps taken to become aware and address the risks identified that will be evaluated.

Crucially, the corporate responsibility to respect human rights goes beyond simple legal compliance: companies are expected to align with internationally recognized human rights standards, even where national governments fall short in meeting their own obligations.

Useful resources:

  • Office of the High Commissioner for Human Rights (OHCHR), The UN Guiding Principles on Business and Human Rights (United Nations 2011)
  • OHCHR, The Corporate Responsibility to Respect Human Rights: An Interpretative Guide (United Nations 2012).

Which human rights are internationally recognized?

The UNGPs define internationally recognized human rights based on two primary sources:

  • The International Bill of Human Rights; and
  • The International Labour Organization (ILO)'s Declaration on Fundamental Principles and Rights at Work.

The International Bill of Human Rights brings together three landmark instruments that have been ratified by most of the world's nations:

  • The Universal Declaration of Human Rights (UDHR, 1948): It was adopted after World War II and established a common standard of fundamental rights and freedoms. Although not legally binding, it serves as the foundation for modern human rights law.
  • The International Covenant on Civil and Political Rights (ICCPR, 1966): This covenant guarantees civil and political rights such as the right to life, privacy, a fair trial, freedom of expression, religion, and association, as well as protection against torture, slavery, arbitrary detention, and discrimination. Countries that ratify the ICCPR (like Belgium) are legally obligated to uphold its provisions and report regularly to the UN Human Rights Committee.
  • The International Covenant on Economic, Social and Cultural Rights (ICESCR, 1966): This instrument protects rights including fair wages, safe and healthy working conditions, freedom of association, the right to education, the highest attainable standard of health, an adequate standard of living, and participation in cultural life. Ratifying countries (like Belgium) must progressively realize these rights, and compliance is monitored by the UN Committee on Economic, Social and Cultural Rights.

The ILO's Declaration on Fundamental Principles and Rights at Work, originally adopted in 1998 and last revised in 2022, provides an authoritative framework on workers’ rights, a central part of the UNGPs. While not a treaty, the ILO Declaration commits all ILO member states (including Belgium) to respect and promote the listed principles, regardless of whether they have ratified the related ILO conventions. This includes upholding five fundamental freedoms:

  • freedom of association and the right to collective bargaining
  • elimination of forced or compulsory labour
  • abolition of child labour
  • elimination of discrimination in employment and occupation
  • a safe and healthy working environment.

These rights are further spelled out in the eight fundamental ILO conventions.

Useful resources:

  • C087 – Freedom of Association and Protection of the Right to Organise Convention, 1948
  • C098 – Right to Organise and Collective Bargaining Convention, 1949
  • C029 – Forced Labour Convention, 1930
  • C105 – Abolition of Forced Labour Convention, 1957
  • C138 – Minimum Age Convention, 1973
  • C182 – Worst Forms of Child Labour Convention, 1999
  • C100 – Equal Remuneration Convention, 1951
  • C111 – Discrimination (Employment and Occupation) Convention, 1958

Importantly, internationally recognized human rights go beyond this baseline. Companies are expected to pay particular attention to groups and individuals who may be especially vulnerable to negative impacts when their activities or business relationships may affect them. This includes Indigenous Peoples, women, children, persons with disabilities, migrant workers, and ethnic or religious minorities. Several international human rights instruments provide specific protections of specific groups.

Useful resources:

Legally Binding Treaties (once ratified)

  • The International Convention on the Elimination of All Forms of Racial Discrimination (ICERD, 1965) – Ratified by Belgium in 1975
  • The Convention on the Elimination of All Forms of Discrimination against Women (CEDAW, 1979) - Ratified by Belgium in 1985
  • The Convention on the Rights of the Child (CRC, 1989) - Ratified by Belgium in 1991
  • The ILO Indigenous and Tribal Peoples Convention (No. 169, 1989) – Not ratified by Belgium.
  • The International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families (ICMW, 1990) – Not ratified by Belgium.
  • The Convention on the Rights of Persons with Disabilities (CRPD, 2006) – Ratified by Belgium in 2009.

Non-Binding Instrument (Soft Law)

  • The UN Declaration on the Rights of Indigenous Peoples (UNDRIP, 2007)

In conflict-affected areas, international humanitarian law (IHL) also applies. All EU member states have ratified the main IHL conventions and protocols, meaning that organisations and individuals — including companies and their representatives — must respect IHL.

What does this mean for Belgian companies?

Belgian companies are expected to uphold the UNGPs – particularly by embedding the corporate responsibility to respect human rights into their policies and practices - in order to meet social expectations and maintain their social license to operate.

The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct

Together with the UNGPs, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct set the global benchmark for responsible business conduct and provide a practical blueprint for how companies can meet their responsibility to respect human rights.

The OECD Guidelines were first introduced in 1976 as recommendations from OECD member states (including Belgium) and other adhering governments to businesses on responsible business conduct. They were revised in 2011 to align with the UNGPs. This update introduced the concept of human rights due diligence and extended it into areas such as environmental protection and climate change. The most recent revision took place in 2023 and expanded responsible business expectations by introducing due diligence across topics such as climate, biodiversity, science, technology, bribery, and lobbying.

The OECD Guidelines are supported by National Contact Points (NCPs) in each adhering country. These national agencies raise awareness and promote the Guidelines - including by providing guidance to companies - and offer a platform for handling complaints for alleged breaches of the OECD Guidelines by companies. They may also support governments' policy efforts to promote responsible business conduct. In Belgium, the NCP is hosted by the Federal Public Service Economy (FPS Economy).

In addition, the OECD Guidelines are complemented by sector- and issue-specific guidance which offer practical direction for companies on how to put these expectations into practice in their daily operations.

Useful resources:

  • OECD, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (2023);
  • OECD, OECD Due Diligence Guidance for Responsible Business Conduct (2018).
  • Belgian National Contact Point (NCP) for Responsible Business Conduct.

What does this mean for Belgian companies?

Belgian companies are expected to align with the OECD Guidelines — particularly by embedding risk-based due diligence into their operations and across their value chains — both as a matter of good practice and to meet the growing expectations of regulators, investors, and civil society.

European (regional) frameworks

Standards and principles in Europe and the Wider European Area

Companies operating in Europe are increasingly expected - and in some cases required - to respect human rights not only in their own operations but across their value chains. These expectations are grounded in a growing body of legally binding frameworks developed by institutions such as the European Union and the Council of Europe.

Together, these frameworks shape a regional legal environment where respecting human rights is no longer just good practice — it is becoming a legal and societal expectation.

Key regional standards relevant to business and human rights

For companies operating in the EU, regional standards - alongside internationally recognized human rights - are highly relevant, as they shape the legal environment in which businesses operate. These include:

  • The European Convention on Human Rights (ECHR) (1950): a Council of Europe treaty, binding on its member states (including Belgium). It guarantees key civil and political rights (e.g. right to life, freedom of association, non-discrimination). Its case law often drives legal reforms at national level, which in turn apply to companies.
  • The Council of Europe Convention on Action against Trafficking in Human Beings (2005): a legally binding treaty requiring states to prevent trafficking, protect victims, and prosecute perpetrators. It applies to all forms of trafficking, including for labour exploitation, and emphasises victim rights and corporate due diligence. Its implementation can affect business obligations, particularly in high-risk sectors and supply chains.
  • The EU human rights and labour law: a wide body of legally binding treaties, directives, and regulations covering civil liberties, worker rights, and social protections. These include laws on working conditions, equal treatment, health and safety, data protection, and access to justice. Together, they support and strengthen the EU's due diligence and sustainability agenda, making respect for fundamental rights a core compliance and governance issue for businesses.
  • The European Social Charter (1961, revised 1996): a Council of Europe treaty, binding on its member states (including Belgium). It guarantees key economic and social rights, such as fair working conditions, health and safety at work, the right to social security, and protection against poverty and social exclusion. Its monitoring body, the European Committee of Social Rights, regularly assesses state compliance, and its findings often inform national labour and social policy reforms, which may also impact company practices.
  • The European Pillar of Social Rights (2017): a concise overview of the 20 key principles aimed at promoting a fairer and more inclusive Europe. Presented in coordination with EU institutions, this booklet lays out the Pillar's structure and objectives clearly.
  • The EU Anti-Discrimination Framework: a comprehensive framework of binding directives prohibiting discrimination on grounds such as race, gender, religion, disability, age, and sexual orientation. These include rules on equal treatment in employment, occupation, and access to goods and services. Together, they make non-discrimination a core legal and reputational issue for businesses.
  • The EU Charter of Fundamental Rights (2000): brings together civil, political, economic, and social rights alongside modern rights such as environmental protection, data protection and consumer protection rights. It is legally binding on EU institutions and Member States. EU regulations and directives (such as the GDPR on data protection) must comply with the Charter, which in practice creates direct obligations for companies.
  • The EU environmental law and policy: a wide body of binding directives and regulations on pollution, biodiversity, climate, and resource use. These reinforce and complement the CSDDD's due diligence obligations, making environmental protection a core compliance issue for businesses.

These instruments form the foundation of the regional legal environment in which companies operate. Building on this foundation, the EU has recently introduced more specific and binding obligations for companies requiring them to respect human rights and the environment in their own operations and across their value chains. The Corporate Sustainability Due Diligence Directive (CSDDD), adopted in 2024, is the cornerstone of this evolving legal framework. It forms part of a broader regulatory framework aimed at upholding corporate sustainability and responsible business conduct across the EU and beyond.

What does this mean for Belgian companies?

For Belgian companies, this growing body of regional standards and legislation signals a shift from voluntary commitments to enforceable obligations. As both EU and Council of Europe member, Belgium is required to transpose these standards into national law, meaning that companies operating in Belgium are subject to them. This legal landscape demands that Belgian companies not only stay informed but actively integrate respect for human rights and the environment into their policies, practices, and across their value chains.

The Corporate Sustainability Due Diligence Directive

The CSDDD makes it a legal duty for large companies to carry out human rights and environmental due diligence (HREDD) in both their own operations and across their "chains of activities". This covers:

  • upstream business partners – suppliers and other partners involved in the production of goods or the provision of services by the company
  • certain downstream business partners – such as those responsible for distribution, transport and storage of the product.

Which companies are subject to the CSDDD?

The CSDDD applies to:

  • Large EU companies with more than 1,000 employees and over €450 million in global turnover; and
  • Non-EU companies with more than €450 million in turnover within the EU market.

Impact on SMEs

Small and medium-sized enterprises (SMEs) are not directly covered by the CSDDD, but they will feel the impact indirectly. Larger companies will require their suppliers to provide information, and put in place certain due diligence measures in order to meet their own obligations. SMEs that want to stay in supply chains will need to align with these expectations.

What standards must companies respect?

The CSDDD specifies which human rights and environmental standards companies must respect.

The human rights (Annex I, Part I) are based on core international instruments already mentioned, including the International Bill of Human Rights and ILO Conventions. Key expectations include:

  • The elimination of child labour or forced labour
  • Fair and adequate wages
  • Safe and healthy working conditions

The environmental standards (Annex I, Part II) draw on major international environmental agreements. Companies must ensure in particular:

  • The protection of biodiversity
  • The prevention of significant pollution
  • Sustainable use of natural resources
  • Contribution to limiting global warming to 1.5°C, in line with the Paris Agreement

Enforcement

The CSDDD establishes two main enforcement mechanisms:

  • Supervisory authorities – each Member State must set up a regulator with powers to request information, investigate companies, act on complaints, order corrective measures, and impose fines.
  • Civil liability – companies can be held liable where they fail to exercise appropriate due diligence and this leads to harm to individuals.

The Omnibus Package

In early 2025 the European Commission proposed an "Omnibus Package", seeking to amend the CSDDD and other EU regulations, with the declared aim of boosting EU competitiveness and fostering long-term prosperity.

On 14 April 2025, the Council of the EU approved the first part of this package —the "Stop the Clock" Directive — which delays the CSDDD's application and transposition deadlines. Member States, including Belgium, must now transpose the CSDDD into national law by 26 July 2027, one year later than originally planned.

The second part of the package — still under negotiation — could bring more substantive changes, such as: limiting due diligence obligations mainly to Tier-1 suppliers (unless companies have "plausible information" of risks further down the chain), reducing the frequency of periodic assessments, increasing employee and turnover thresholds, introducing "value chain caps" that would limit information requests to SME suppliers, and even removing the civil liability provision.

The CSDDD is the cornerstone of the EU's sustainability framework, around which other key pieces of legislation align and converge.

Useful resources:

  • European Commission, Corporate Sustainability Due Diligence Directive (CSDDD, 2024).
  • European Commission, Omnibus Proposal (2025).

What does this mean for Belgian companies?

For Belgian companies, the CSDDD introduces a legal duty to implement HREDD. Those that fall within the scope of the Directive will need to review and, where necessary, adapt their governance structures, policies and processes to ensure compliance. Even companies not directly subject to the Directive — such as Belgian SMEs — will increasingly be expected to provide information and demonstrate responsible practices to remain part of the value chains of larger businesses. As Belgium prepares to transpose the Directive into national law, companies operating in the country would be well advised to begin aligning with these expectations now to avoid legal and reputational risks and to maintain their competitiveness in the EU market.

The Broader EU Framework

The EU is building a comprehensive set of rules to strengthen corporate sustainability which includes:

  • The Conflict Minerals Regulation (CMR) (2017): obligates EU importers of tin, tungsten, tantalum, and gold (3TG) from conflict-affected or high-risk areas to check their supply chains and conduct due diligence to prevent their trade from financing armed conflict or human rights abuses.
  • The EU Taxonomy Regulation (2020): establishes criteria to define whether an economic activity qualifies as "environmentally sustainable". In addition to having to contribute to environmental goals and "doing no harm" to other environmental goals, activities must be carried out in accordance with the OECD Guidelines.
  • The Corporate Sustainability Reporting Directive (CSRD) (2022): requires large companies to report in line with the European Sustainability Reporting Standards (ESRS). This means disclosing their actual and potential sustainability impacts, the related financial risks and opportunities, and how these are being managed. The ESRS also include mandatory reporting on due diligence processes, so companies must show how they identify, prevent, and address human rights and environmental risks.
  • The EU Regulation on Deforestation-Free Products (EUDR) (2023): Requires companies trading certain commodities (such as beef, cocoa, coffee, palm oil, rubber, soya and wood) and derived products (like leather, chocolate, or furniture) on the EU market to prove that these goods are not linked to deforestation or forest degradation. Companies must trace supply chains back to the plot of land and provide due diligence statements before placing products on the EU market.
  • The EU Batteries Regulation (EUBR) (2023): imposes due diligence and sustainability requirements across the life cycle of batteries (from sourcing raw materials to recycling), including human rights, environmental, and circular economy standards. In July 2025, its entry into force was delayed by two years to August 2028 in order to give industry and third-party verification bodies more time to prepare.
  • The EU Forced Labour Regulation (EUFLR) (2024): prohibits companies from placing, making available, or exporting products made with forced labour.

Useful resources:

  • Reflection Paper: Towards a Sustainable Europe by 2030 (2019)
  • EU Action Plan on Human Rights and Democracy 2020-2024 (2020)

What does this mean for Belgian companies?

Several of these instruments — such as the Conflict Minerals Regulation and the Corporate Sustainability Reporting Directive — have already been transposed into Belgian law, creating immediate compliance obligations for Belgian companies. Others, such as the EU Deforestation-Free Products Regulation and the Forced Labour Regulation, are directly applicable and will be enforced without the need for national transposition. Depending on their size, sector, and role in the value chain, companies may face direct legal duties or be required to support larger business partners in meeting theirs. This means strengthening internal systems, improving traceability, and preparing to demonstrate how human rights and environmental risks are identified and addressed.

National Frameworks

National-level regulatory developments and obligations

At the national level, an increasing number of countries have adopted mandatory HREDD laws.

Developments in Belgium

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.

Useful resources:

  • The Belgian Constitution (Official English Translation, 2021)
  • Belgium: Labour and Employment Laws & Regulations (ICLG, 2025)
  • Labour and Human Rights – Federal Institute for the Protection and Promotion of Human Rights (Belgium)
  • Decent Work Toolbox - Belgium Development Agency
  • Business and Human Rights – FPS Foreign Affairs (Belgium)

What does this mean for Belgian companies?

The growing number of national HREDD laws across Europe — including in key trading partners like France, Germany, and Norway — reflects rising expectations for companies to identify, prevent, and address human rights and environmental risks. For Belgian companies with operations, subsidiaries, or business relationships in these countries, this may require compliance with foreign legal requirements or adapting their practices to maintain access to markets and key business relationships.

Developments within European Countries

In Europe, relevant legislative developments include:

  • The French Duty of Vigilance Law (Loi sur le devoir de vigilance, 2017): applies to very large French companies (with more than 5,000 employees in France or 10,000 globally). It requires them to implement and publish a "vigilance plan" detailing how they identify, prevent, and address serious human rights and environmental risks in their own operations, subsidiaries, and established supply chain relationships. Companies can face civil liability if harm occurs due to a failure to implement these measures.
  • The German Supply Chain Due Diligence Act (LkSG, 2021): applies to large German companies (since 2024, those with more than 1,000 employees). It obliges them to carry out due diligence in relation to human rights and certain environmental risks in their own operations and those of their direct suppliers, and in some cases indirect suppliers if the company has "substantiated knowledge" of risks. The Act is enforced by the Federal Office for Economic Affairs and Export Control (BAFA), which can impose significant fines and exclude non-compliant companies from public procurement. There is growing uncertainty around the LkSG's future since in mid-2024, the German government floated the idea of pausing the Act for two years pending the rollout of the CSDDD in 2026.
  • The Norwegian Transparency Act (Åpenhetsloven, 2021): applies to large and medium companies (whether Norwegian or foreign) offering goods or services in Norway that meet certain thresholds (exceeding at least two of the following criteria: more than 50 employees; annual turnover above NOK 70 million; or total assets above NOK 35 million). It requires them to conduct due diligence in relation to human rights and decent work, publish an annual report on their efforts, and respond to public requests for information.

Outside of Europe, other countries, including Brazil, Canada, Colombia, Mexico, South Korea, and Thailand, New Zealand, amongst others, are considering similar laws.

Useful resources:

  • French Corporate Duty of Vigilance Law (Unofficial English Translation by the European Coalition of Corporate Justice) (2016)
  • German Act on Corporate Due Diligence Obligations for the Prevention of Human Rights Violations in Supply Chain Act (LkSG, Official English Translation, 2021)
  • Norwegian Act relating to enterprise's transparency and work on fundamental human rights and decent working conditions (Transparency Act, English Translation, 2021)

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