On 20 September 2026 Jeremy Prepscius at ILLÆSA refreshed a briefing on corporate due diligence. For brands, factories and buyers in textiles, the useful part is short. Two duties now sit side by side, and both are judged on what you can show.

This news item is a reading of that briefing. It is not legal advice. The full piece is The evolving due diligence regime: the horizon has arrived.

Do the work, and keep forced labour out of the product

The first duty is an obligation of means. You do risk-based due diligence, and you are judged on the quality of that work. In the EU this sits in the Corporate Sustainability Due Diligence Directive (CSDDD). An amending directive has been in force since 18 March 2026. Member states must transpose it by 26 July 2028. It applies from 26 July 2029.

The revised thresholds are 5,000 employees and €1.5 billion in net worldwide turnover. For a company outside the EU, the turnover test is €1.5 billion inside the EU. Penalties can reach 3 percent of worldwide turnover. A smaller company is not outside the system. It often supplies a customer who stays in scope, and that customer will still ask for proof. French and German supply-chain laws are already in force.

The second duty is an obligation of results. If forced labour is in the product, the product can lose the market, however careful the file. The EU Forced Labour Regulation applies in full from 14 December 2027. The Commission’s guidelines say due diligence is taken into account, and that it does not by itself keep a product on the market. A ban follows the product, so a later buyer can inherit a supplier’s problem.

What is enough

The briefing describes minimum compliance as intentional, proportionate and effective. A control that nobody uses to decide anything is a report, not a control. The practical list is:

  • Trace the chain where the harm and the exposure meet.
  • Give workers a channel they trust, and a remedy that reaches them, including repayment of recruitment fees.
  • Look at purchasing practices. Price, lead time and payment terms shape working hours and debt.
  • Keep an evidence file that shows decisions changing, not only policies.

Products are starting to carry that evidence with them. The briefing places Digital Product Passport standards next to deforestation rules, carbon-border measures and stricter rules on green and social claims. For a garment the question is concrete: can you show this chain, and can the next person in the chain see the same proof?

ILLÆSA’s experience is that each of these building blocks takes eighteen months or more. None of it can be assembled on the day a shipment is stopped at the border.