Who this paper is for – and what you will get from it
This discussion paper is for practitioners, experts, civil society, trade unions, worker organisations, consultants, service providers, academics and others working on, implementing or advising on human rights due diligence (HRDD) / corporate sustainability due diligence under the EU Corporate Sustainability Due Diligence Directive (CSDDD).
It provides a practical structure for thinking about the growing use of artificial intelligence (AI) in HRDD: where AI could be used, what opportunities this might create, and what questions we should be asking as its use expands.
It is intended as a starting point for further discussion, rather than a set of answers.
Why this conversation matters now
AI is here. Its capabilities are expanding rapidly, and companies are increasingly exploring how it can support different components of HRDD.
We hear about AI being used to analyse large volumes of information, identify patterns and potential risks, support supply chain mapping, review grievances and audit findings, monitor developments, draft disclosures and help teams manage increasingly complex due diligence processes.
This use of AI in HRDD is likely to grow. Expectations of companies to conduct effective HRDD are becoming more firmly embedded in regulation and stakeholder expectations. And at the same time, AI systems are becoming more capable, more accessible and increasingly integrated into the tools and systems companies already use.
This brings us to a central question:
Can AI help strengthen the quality, scale and effectiveness of HRDD? Or does it risk accelerating superficial, compliance-driven and overly technocratic approaches that weaken meaningful engagement, accountability and outcomes for people?
We are at an important juncture.
Decisions being made now – about where AI is introduced, what it is asked to do, what information it relies on, where humans remain involved, and how its outputs are questioned and tested – will shape how HRDD evolves in practice.
Objective of the paper
Over the past year, through conversations with company practitioners, experts and advisors, we have heard both a growing range of ways in which AI is being used for HRDD, as well as a growing number of questions about what that use means in practice.
This paper brings those conversations together and provides a practical framework for interrogating the use of AI against the expectations of HRDD itself.
It works through the different elements of the due diligence process and asks: Where could AI potentially help? What could it enable? Where could it create pitfalls? What questions could practitioners be asking?
We have found that grounding the discussion on AI in the actual expectations of HRDD, a number of which are in turn reflected in the EU CSDDD, helps move the conversation from the abstract to the practical: whether, where and how it can contribute to more effective due diligence and better outcomes for people.
Our intention is not to advocate for or against the use of AI in HRDD, nor to provide definitive answers. It is to provide a structure for a shared and evolving conversation – one that can help companies make more informed choices about how they use AI, ask better questions of AI providers, and identify the safeguards and human judgment needed along the way
This discussion paper delves into possible AI uses (potential opportunities), as well as questions to consider (food for thought) as we use AI in this way. We go through this use of AI for each component of HRDD, as well as policy and embedding. This discussion paper then concludes with eight themes that have surfaced consistently across our discussions on AI and HRDD regardless of which stage of the due diligence process we are considering.
To be clear, by referencing a possible use of AI in this paper, we are not advocating for this use or suggesting this is a helpful use of AI for HRDD. Rather, we are surfacing that this is a use that practitioners are already seeing as an opportunity, or are likely to see as an opportunity moving forward, which can in turn inform a discussion related to how to ensure this use contributes to meaningful HRDD in practice.
