The EUFLR does not require companies to implement new due diligence systems in advance of an investigation. However, companies that build both response readiness and forced-labour-sensitive preparedness before an investigation is triggered are significantly better positioned to avoid escalation and to demonstrate credibility to authorities. LRQA recommends immediate action in two areas.
1. Build responsible readiness
Response readiness means having the people, processes, and documentation systems in place to respond to an investigation quickly and credibly, before one is ever triggered. This includes:
- Identifying an executive owner and a cross-functional team responsible for EUFLR investigations.
- Defining a clear RACI matrix covering who responds to the authority, who gathers documentation, and who manages internal and external communications.
- Establishing a documented workflow for the preliminary phase (30-working-day window) and the formal investigation (30-60 working days).
- Conducting tabletop simulations to test response capability under realistic scenarios.
- Ensuring rapid evidence retrieval routines are in place across business units and supply chain systems.
Having a defined response procedure means identifying a specific, accountable person who knows when and how to act, who to contact internally to trace product information, and how to gather and submit documentation to the competent authority. This capability can be built now, independently of the forthcoming guidance.
2 . Make due diligence forced-labour-sensitive
Many companies already have human rights due diligence (HRDD) or responsible sourcing systems in place. However, LRQA consistently finds that these systems are designed to address human rights risks broadly and are not sufficiently calibrated to detect, prioritise, and respond to forced labour specifically.
Making due diligence forced-labour-sensitive means several things in practice. Risk analysis needs to be sensitive to forced-labour indicators, not just general labour rights risks. A product-level lens is required: which products, in which supply chains, carry the highest forced-labour exposure? Supply chain traceability must be built beyond first- and second-tier suppliers, particularly for high-risk commodities and geographies. And mitigation and remediation measures must be specifically designed to address forced-labour cases, not just general non-conformances.
The EU Forced Labour Regulation represents a fundamental shift: forced labour is now a market-access issue, not just a reporting or disclosure topic. Every company placing, making available, or exporting products on or from the EU market, regardless of size, sector, or turnover, is within scope.
LRQA's view, grounded in practical experience across forced-labour investigations, auditing, and remediation, is that companies face a genuine and time-sensitive choice. Waiting for official guidance before acting is a risk: the systems, teams, and evidence packs that will matter most in an investigation take time to build, and enforcement experience is expected to intensify from the second year of application onward.
Addressing EUFLR should never be a standalone compliance exercise. It is a cross-functional exercise involving buying, sustainability, compliance, and legal departments together; organisations need to use the efficiencies of existing due diligence systems and broader corporate responsibility mechanisms rather than treating EUFLR in isolation. And it is not only a compliance exercise: companies that address EUFLR are better equipped to manage supply chain risk, reduce disruptions, and build more resilient sourcing relationships. The benefits extend well beyond regulatory compliance.
Forced labour remains prevalent worldwide, and many European companies may be contributing to the situation without knowing it. This regulation creates both the legal imperative and the practical opportunity to address that.
The most resilient approach focuses on two pillars: response readiness, meaning clear roles, timelines, and workflows enabling companies to respond quickly and credibly to any investigation; and preparedness, meaning forced-labour-sensitive due diligence, credible evidence packs, and worker-centred approaches that can withstand scrutiny from investigators. Companies that prepare proactively now will be better positioned once enforcement matures and guidance takes effect, and will be building more responsible, resilient supply chains in the process.
