The UN Office of the High Commissioner for Human Rights (OHCHR) released its report, Using Digital Tools for Stakeholder Engagement: Aligning Corporate Practice with the Guiding Principles on Business and Human Rights (May 2026), submitted to the Human Rights Council's sixty-second session.
Human Level’s Take:
- Businesses are increasingly turning to a widening range of digital tools, including chatbots, mobile surveys, automated translation and case management systems to engage workers in their value chains. But reaching more people is not the same as engaging with them meaningfully.
- OHCHR’s latest report sets out where these tools can help strengthen human rights due diligence under the UN Guiding Principles on Business and Human Rights (UNGPs), and where they risk falling short.
- Digital tools can reach workers that traditional engagement cannot, including those in remote locations, in informal work, where there are limited protections for union rights, or where engagement with local unions is difficult. They can also exclude the very people they are meant to reach, particularly those with low literacy or limited access to devices and networks.
- However, one point holds throughout: the corporate responsibility to respect human rights cannot be outsourced to technology, however sophisticated.
- A recurring tension is the relationship between digital tools and trade unions. Tools designed for individual workers can risk bypassing collective structures, even where no harm is intended.
- For companies already using or considering technological solutions for stakeholder engagement, the report sets out 12 practical questions businesses can ask providers to assess the suitability and limitations of tools (also included in a standalone tool). These questions cover worker safety, privacy, human oversight of AI-driven systems and access to remedy.
Some key takeaways:
- The use of digital tools to facilitate stakeholder engagement is expanding rapidly, bringing both opportunities and risks: OHCHR identifies a wide and growing range of digital tools being used for stakeholder engagement, including reporting apps, chatbots, mobile phone surveys, automated translation, remote meeting software and specialised case management systems. These tools can help companies reach people who would otherwise be difficult to engage, including workers in remote locations, in informal employment, where there are limited protections for union rights was poor or where engagement with local unions is difficult. They can also surface granular information to support human rights due diligence. However, the report finds that tools can also exclude people with low literacy or limited access to devices and networks, risking exacerbating the very gaps they are designed to help close. There may also be a risk of undermining trade unions or other workers’ organisations by bypassing collective representation structures. In addition, some technologies can have a “depersonalizing” effect, reducing complex human experiences to data points, and can risk entrenching existing power imbalances between companies and affected people. OHCHR states that meaningful stakeholder engagement, as set out in the UNGPs, requires that stakeholders are heard and understood and that their concerns are properly reflected in decision-making. One-way information-gathering tools do not meet this standard on their own.
- Businesses carry non-delegable responsibility for how these tools are used: The report is clear that the corporate responsibility to respect human rights cannot be outsourced to technology or third-party digital tool providers. It sets out that businesses need to ensure they have the technical knowledge and human rights expertise to assess the advantages, disadvantages and workability of different tools in specific settings, including through a dedicated due diligence process for the tools themselves. Companies are encouraged to consider how a tool integrates with wider human rights due diligence and remedy strategies, including clear pathways for follow-up and escalation. For tools reaching workers in value chains, OHCHR highlights the importance of consulting trade unions and other workers' organisations, both to draw on their expertise and to assess the risk that a tool could undermine collective engagement structures. As AI-driven and automated systems become more prevalent, the report also flags emerging challenges for regulators, including the risk that they approve stakeholder engagement methodologies they do not fully understand the potential implications of.
- OHCHR sets out 12 practical questions to assess stakeholder engagement tools for workers: The report's central guidance takes the form of 12 questions that businesses, tool providers, regulators and other actors can use to assess a tool's alignment with the UNGPs. These questions cover the tool provider's own human rights commitments and expertise, the extent of worker and union involvement in a tool's design, safeguards for worker safety and privacy, the availability of choice in how workers engage, arrangements for human intervention where needed, and the transparency and scrutiny of any AI-driven decision-making. Digital tool clients, including businesses, are encouraged to conduct meaningful stakeholder engagement in alignment with the UN Guiding Principles on Business and Human Rights, keeping engagement approaches under constant review in light of technological innovation and lessons learned. Recommendations include drawing on the report's findings when developing strategies to integrate stakeholder engagement tools into broader human rights approaches, and using the 12 questions to guide the assessment of the suitability and limitations of digital tools aimed at engaging workers.
