Regulatory design, institutional pressures and the coupling of human rights due diligence

Purpose This paper evaluates how the design of the Corporate Sustainability Reporting Directive (CSRD) influences corporate disclosures on modern slavery and human rights due diligence (HRDD) in global supply chains. It aims to examine whether this new regulatory framework addresses the limitations of earlier disclosure laws, particularly in overcoming organisational policy−practice coupling and superficial compliance. Design/methodology/approach A deductive content analysis was conducted on 21 sustainability reports from companies headquartered in Ireland, assessing disclosures under the European Sustainability Reporting Standards, specifically Social Standard 2 (S2) on value chain workers. Semi-structured interviews with 32 sustainability and supply chain managers provided complementary insights into the reporting process and practical challenges of HRDD implementation. Findings While most companies had a basic HRDD policy and conducted various risk assessments for their tier-1 suppliers, far fewer reported meaningful engagement with value chain workers or effective remediation mechanisms. The CSRD’s requirement for double materiality assessment and third-party assurances appears to strengthen procedural transparency. However, companies continue to use proxies in place of direct worker engagement, and audit-based disclosures rarely capture structural risks such as forced labour. Originality/value This paper offers early empirical evidence on supply chain HRDD disclosures under the CSRD. It elaborates on the concept of the double materiality assessment and highlights how regulatory designs can tighten HRDD policy−practice coupling. The findings advance debates on the effectiveness of reporting frameworks in tackling modern slavery within sustainable supply chain management.