WBA's response to the consultation on the CSDDD implementation guidelines

The guidelines should provide practical guidance on risk-based due diligence, including how companies identify, assess and act on human rights risks in their business relationships. This should help companies move from general human rights commitments to evidence of risk assessment, prioritisation, action taken and effectiveness tracking.

WBA’s 2026 Social Benchmark shows that companies are still much stronger on general commitments than on extending expectations and action through business relationships. Only 17% identify human rights risks in their supply chains, 10% assess human rights risks in their supply chains, and 9% disclose action taken to address these risks in supply chains. While 27% disclose the results of their human rights risk and impact assessments, only 16% provide an action example on a salient human rights issue. This suggests that guidance should focus on how companies move from risk identification and assessment to action, stakeholder engagement and effectiveness tracking.

The guidelines should also distinguish grievance mechanisms from remedy. A grievance mechanism is an important channel for raising concerns, but it is not in itself evidence that remedy has been provided. In the 2026 Social Benchmark, 36% of companies meet the requirement on providing grievance mechanisms for workers. At the same time, only 9% of companies disclose a commitment to remedy, and only 4% expect business relationships to commit to remedy. This points to the need for guidance that helps companies move beyond complaints channels by clarifying what credible remedy requires in practice, including accessible mechanisms, meaningful outcomes for affected people and appropriate remedial measures.

Among the companies assessed, Heineken demonstrates strong remedy practices by linking a specific adverse human rights impact to both concrete remedy and systemic improvements. In response to labour violations affecting transport workers in Brazil, the company provided affected workers with accommodation, financial assistance and emotional support, while investing approximately €3.6 million in new facilities for truck drivers across its breweries. Following a comprehensive review, it introduced a more rigorous supplier-governance process, demonstrating how lessons learned informed changes aimed at preventing recurrence

The guidelines should explain the practical steps companies can take to move from a general wage commitment to credible implementation of living wage. This should include setting a time-bound target or action plan, using a credible living wage benchmark or methodology, measuring wage or income gaps, and disclosing progress and coverage.

WBA’s 2026 Social Benchmark shows that living wage performance remains a big gap: fewer than 5% of companies disclose that they guarantee a living wage for their direct workforce, and only 3% report action to support living wages in supply chains.  

However, emerging practice shows implementation is possible: 131 companies now disclose the dataset or methodology they use, up from 49 in 2024, and 47 additional companies disclose achievement of, or credible pathways toward, living wage coverage. The guidelines should build on this momentum by making clear that broad commitments to “fair” or “decent” pay are not enough unless they are backed by recognised benchmarks, gap assessments and concrete plans.  

The guidelines should also recognise collective bargaining, responsible purchasing practices, worker representation and social dialogue as critical mechanisms for setting and achieving adequate wages in practice. WBA data shows that companies meeting collective bargaining disclosure requirements are three times more likely to guarantee a living wage. However, fewer than 30% of companies disclose the percentage of their workforce covered by a collective bargaining agreement, and only 1% disclose actions to support freedom of association and collective bargaining in business relationships.

Neste provides a useful example of credible implementation beyond a general commitment. The company states that it pays all employees a living wage and has set a 2030 target to promote living wages in its supply chains, including requiring strategic contractors and suppliers to pay a living wage. In 2024, Neste completed an internal living wage gap assessment using Fair Wage Network data, and assessed the living wage practices of 11 renewable raw material suppliers through supplier onboarding and sustainability audits. 

The guidelines should clarify the types of evidence that demonstrate credible responsible purchasing systems, including buyer-side capacity planning, timely payment systems, internal review of purchasing decisions and supplier feedback mechanisms. They should also encourage companies to monitor whether purchasing practices contribute to actual worker risks, including excessive overtime, wage violations and unsafe working conditions.

WBA’s Corporate Human Rights Benchmark (CHRB) shows a clear gap between supplier expectations and buyer-side support. While 87% of assessed companies reflect human rights expectations in supplier contracts, companies meet on average only 23% of responsible purchasing requirements. Only 8% of companies include responsible purchasing commitments in contracts. This suggests that many companies are setting expectations for suppliers, but far fewer are embedding their own purchasing responsibilities into commercial terms and procurement practices.

Examples of stronger practice can help clarify what credible implementation looks like. Puma, headquartered in Germany, provides a useful example of buyer-side systems to reduce supplier pressure. The company aligns seasonal production plans with negotiated supplier capacity, requires suppliers to declare open production capacity, controls subcontracting through prior authorisation, and uses centralised procurement and digital payment systems to improve transparency and timely payments. This illustrates how responsible purchasing can move beyond policy commitments and become embedded in procurement systems. 

The guidelines should clarify the evidence companies should provide to demonstrate meaningful stakeholder engagement across the due diligence process. Companies should show not only who was engaged and what issues were raised, but how input from affected people and their legitimate representatives shaped risk assessment, prioritisation, action plans or remedy. Expert reports, NGO input and industry initiatives can support scoping, but should not replace direct engagement with affected stakeholders, especially workers, communities, indigenous peoples and informal workers.

WBA’s 2026 Social Benchmark shows that stakeholder engagement is still one of the weakest parts of human rights due diligence practice. Only 9% of companies meet the element on engaging stakeholders and experts in Human rights risk identification, 12% engage stakeholders in risk assessment, and only 4% engage stakeholders in action decisions. This suggests that companies are still not systematically using stakeholder input to shape due diligence decisions.

Some leading companies assessed by WBA already demonstrate more structured stakeholder engagement in practice. Enel conducts assessments and consults a broad range of potentially affected stakeholders, including direct and indirect workers, local communities, Indigenous and tribal peoples, trade unions and customers. It uses and discloses several engagement methods, including interviews, focus groups and surveys. Its structured, geographically broad three-year assessment cycle demonstrates that stakeholder engagement is ongoing and systematically embedded in its approach to identifying and assessing human rights risks and impacts. 

The CSDDD guidelines will be most effective if they provide practical orientation on credible due diligence implementation. WBA stands ready to support this process by sharing insights from its global benchmark data, company-level evidence and practical examples across human rights due diligence, living wage, responsible purchasing and stakeholder engagement. Drawing on our assessments of the world’s most influential companies, we hope the guidelines can help create a clearer basis for implementation and ultimately support due diligence that leads to meaningful change for rights-holders.