The Organization for Economic Cooperation and Development (OECD) released its 2026 OECD Responsible Business Outlook: Making Commitments Count (June 2026). The report is based on publicly disclosed information of the 10,000 largest listed companies globally and government policies across 52 countries.
Human Level’s Take:
- The status of responsible business conduct is mixed, according to the OECD’s analysis of how the 10,000 largest listed companies globally perform against the OECD due diligence framework.
- Most companies assessed have commitments covering at least one responsible business conduct issue (with corruption and reducing greenhouse gas emissions at the top of the list and forced labour, child labour and human rights following). But far fewer companies are reporting on how they implement these commitments in practice: 45% report on policies and management systems and less than 20% report on the measures they take to address impacts.
- Implementation especially lags in the supply chain, where companies tend to have higher human rights and environmental risks but lower visibility and leverage. For example, only 7% integrate social requirements into purchasing practices and less than 20% assess supplier risks against social and environmental criteria. Oversight also drops beyond Tier 1 suppliers, with fewer companies reporting on impacts in Tiers 2 or 3 of the supply chain.
- Another challenge: stakeholder engagement and remedy — foundations for strong human rights due diligence — are uncommon. Only 8% of companies report engaging stakeholders on human rights issues, 17% have formal human rights grievance mechanisms, and just 10% commit to providing remedy.
- Although State-driven responsible business conduct is increasing through mandatory due diligence, sustainability reporting requirements, trade agreements, public procurement standards and incentives, companies continue to face barriers to effective due diligence. Data collection challenges, restrictions on audits, and concerns about reputational or legal risks all constrain implementation and disclosure.
- The findings illustrate that the drivers for responsible business conduct are there, but companies need to get a layer deeper than policies and commitments by putting the expectations of due diligence into practice. Priority areas for companies: deeper supplier engagement and more meaningful stakeholder engagement, effective grievance mechanisms that enable remedy, and integrating human rights principles into core business operations.
Some key takeaways:
- Policy commitments are widespread but implementation is relatively low: Assessing against the OECD due diligence framework, the report find that commitments to responsible business are common. For example, 69% of large listed companies have public commitments on at least one issue, with the most common commitments related to corruption and reducing greenhouse gas emissions, followed by forced labour, child labour and human rights. However, implementation of these commitments lags behind. Companies tend to report more on their policies and management systems (45%) rather than other aspects of due diligence, like measures they have taken to address impacts (fewer than 20%). The implementation gap is especially clear in company reporting on their supply chains: while around half have social or environmental selection criteria for suppliers, less than 20% evaluate supplier risk based on those criteria and only 7% report integrating their social supply chain policy into purchasing practices. Another gap is in stakeholder engagement and remediation of human rights issues. Just 8% of companies report that they engage with stakeholders on human rights issues. Seventeen percent have a formal grievance mechanism on human rights and 10% commit to providing remedy.
- Barriers to implementation and disclosure: The report identifies potential barriers to implementing and disclosing on due diligence. One barrier is that companies may have limited visibility and leverage over upstream suppliers beyond Tier 1, where the most significant risks and impacts typically sit. Looking at 450 of the companies, around 70% socially audit Tier 1 suppliers, but only 35% audit Tier 2 or Tier 3 suppliers, which may limit their visibility. Some companies face challenges obtaining data due to capacity constraints, restrictions related to data protection or national security, or limitations on on-the-ground audits and engagement. Legal and practical barriers can also impact reporting. For example, only 7% of companies disclose salient human rights issues and 6% disclose outcomes of supplier monitoring, which could suggest that they face particular challenges measuring and communicating on human rights impacts, which can come with reputational and liability risks that disincentivise public reporting. When it comes to double materiality disclosure on key social and environmental issues under the European Sustainability Reporting Standards, the OECD finds that more companies report on a given issue than report that the same issue is financially material for their business, suggesting that key issues (especially workers in the value chain, water and marine resources, and the circular economy) are likely not being viewed through a financial risk lens. This could suggest challenges for companies in assessing and reporting on certain risks and impacts, but it could also mean that there is a lack of real or perceived incentives to address these impacts.
- Mandatory due diligence regulation and responsible business conduct policy is rising: Eighty-four percent of OECD Member countries and 67% of countries that adhere to the OECD Guidelines for Multinational Enterprises (MNE Guidelines), as well as some non-adhering countries, have introduced due diligence regulation. This includes sustainability reporting rules, due diligence requirements, and product- or market-based measures. More countries are also integrating responsible business conduct into their trade agreements. Since 2020, 67 of the 186 trade and investment agreements signed by countries adhering to the MNE Guidelines included clauses on responsible business conduct, and 73% of these 67 agreements were signed with non-adhering countries. Other governments are leveraging public procurement frameworks to promote responsible business conduct among their suppliers. In addition, 29 of the countries adhering to the MNE Guidelines use incentives to promote stronger responsible conduct by business, which include preferential terms for grants, loans or other financial support based on RBC performance; tax credits or benefits; incentives linked to permitting, licensing, company registration, other administrative processes; trade and investment facilitation services; and government-backed trademarks or labels. When it comes to remedy, all adhering countries provide State-based grievance mechanisms for social and environmental harms, and 36 countries have taken one or more steps to reduce barriers to accessing remedy. This is increasingly enshrined in due diligence legislation, where direct or indirect expectations to provide remedy or implement a grievance mechanism are present in half of due diligence legislation introduced in adhering countries.
