The globalization of human rights risks in supply chains has precipitated significant divergence in mandatory Human Rights Due Diligence (HRDD) legislation across nations. This study uses a most-similar case design to compare legislative frameworks in France, Germany, and the US, analyzing differences in liability logic, enforcement mechanisms, and remedial effectiveness. Key findings show legal traditions set liability foundations, and business-civil society bargaining intensity determines legislative stringency. The core contribution shows a positive link between "structural capacity to bypass corporate law barriers" and legislative effectiveness. France rebuilds corporate purpose via civil joint liability, Germany maintains limited liability through administrative compliance, and the United States stays stuck in greenwashing due to shareholder primacy. This research proposes differentiated governance pathways, enhancing judicial activism in civil law, exploring equity innovations in common law, and establishing an transnational tort database certified by International Labour Organization (ILO). The study offers a layered framework for localizing UNGPs and adaptive solutions for emerging economies.
Yu‐Tong Mu (2025) studied this question.