Reflections of the 2026 OECD Forum on Due Diligence in the Garment and Footwear Sector

At the 2026 OECD Forum on Due Diligence in the Garment and Footwear Sector, one theme kept surfacing.

Crisis is not the exception. It’s the operating environment.

Tariffs. Energy transitions. Ultra-fast fashion. Geopolitical instability. Climate shocks. Algorithms that fuel over-consumption.

And through all of it, the same question:

Who absorbs the shock?

The worker didn’t create the disruption.

The worker didn’t design the tariff regime.

The worker didn’t build the algorithm.

And yet, too often, the worker carries the cost.

Regulation as a signal of trust

In the opening session, government representatives from Cambodia and Germany spoke about collaboration across the supply chain. Not as a nice-to-have. As a necessity.

Dr Bärbel Kofler, Germany’s Parliamentary State Secretary, made it clear: mandatory human rights due diligence is not a punishment. It is a framework of trust.

Germany’s experience with regulating due diligence shows something important. Many companies feared it. Most now manage it. Some even thrive within it.

The human rights framework emerging across the EU is not about perfection. It’s about process. About embedding due diligence into the DNA of how a company operates.

And that changes the conversation.

Because when due diligence becomes mandatory, it stops being optional. It stops being marketing. It becomes infrastructure.

Resilience is built before the crisis

From a brand perspective, disruptions are constant.

VF Corporation, parent company of The North Face, Timberland and Vans, spoke candidly about tariffs eating into margins. They’ve absorbed costs. Adjusted their supply chain. Ringfenced labour costs in negotiations with suppliers. Taken price increases on high-demand products.

There’s an important detail here: ringfencing labour costs.

When a brand chooses to protect wages during a tariff shock, it signals something profound. It signals that labour is not a variable cost to squeeze.

But this requires margin. And margin requires foresight.

On the manufacturing side, Saqib Shahzad of Sapphire Diamond Fabrics in Pakistan described the opposite pressure: lack of continuity of orders since COVID. Without predictable orders, factories can’t plan production beyond the year. They can’t guarantee stable salaries. Worker retention becomes fragile.

Add to this the cost of compliance, over $120,000 annually dedicated to certifications, with 40+ certifications to manage.

Convergence of certification systems is a welcome development. But the larger point is this: instability at the top cascades downward.

Purchasing practices are not neutral. They shape working conditions.

If wages were not in competition

Christina Hajagos-Clausen of IndustriALL Global Union said something simple and radical: if we could take wages out of competition, it would be a game-changer.

Collective bargaining agreements. Multi-stakeholder industrial relations. Agreements like the Accord and ACT. These mechanisms create stability and trust across the supply chain.

Trust is not soft. It is structural.

And this is where stakeholder engagement becomes more than a consultation exercise. It becomes governance.

The missing millions

One of the most powerful sessions focused on informal workers, the “missing millions” in apparel supply chains.

Home-based workers. Waste pickers. Informal labourers operating beyond Tier 1 and Tier 2.

A London-based brand shared the experience of discovering “invisible workers” in their supply chain. Instead of retreating, they met with lenders and investors. They acknowledged the issue. They partnered with local intermediaries and international NGOs to reach those workers.

Recognition is the first step in any human rights framework.

If your due diligence does not include informal work, it is incomplete.

The data tells a sobering story

Anithra Varia from the Business and Human Rights Resource Centre presented findings from KnowTheChain. 65 of the largest apparel brands were assessed.

The average score? 21 out of 100.

34 companies scored zero on purchasing practices.

77%  sourced from at least one extra high-risk country. Only one disclosed this transparently.

The average worker voice score? 15 out of 100.

Let that sink in.

In an era of volatility, most workers have no meaningful channel to influence the conditions that shape their lives.

This is not a gap in policy. It is a gap in listening.

Current due diligence tools were built for a slower world

Several speakers challenged whether current due diligence tools are keeping pace with the speed of manufacturing models.

Mapping and disclosures are necessary. But they are not sufficient.

If we want early warning systems, we need worker voice monitoring, continuous, real-time insight directly from workers themselves.

Worker voice monitoring is not a replacement for audits. It is a complement. It introduces dynamism into due diligence. It reflects lived experience rather than periodic snapshots.

If workers cannot articulate pressures as they arise, brands and governments are always responding too late.

Ultra-fast fashion and the regulatory response

Ultra-fast fashion exacerbates social risks. Working conditions, remuneration, and social dialogue are all under strain.

The French government outlined concrete measures: penalties for misleading environmental claims, enforcement on cookie policies, inspections of small parcels, and, from March 2026, a €2 “small parcel tax” to fund customs controls. The EU is removing the €150 customs exemption and introducing a presumed importer status for platforms.

Regulation is catching up.

But here’s the uncomfortable truth: regulation will always lag innovation.

Which means brands must lead, not wait.

Reformation shared how small production runs, close value-aligned partners, and dedicated production lines enable speed without chaos. They actively seek anonymous supplier feedback on purchasing practices and adjust accordingly.

This is stakeholder engagement in action. Not performative. Operational.

Systems thinking, not factory thinking

Eunice Kim from ShinWon Corporation emphasised continuous monitoring, real-time working hours data, ongoing metrics, and improvement cycles.

Not compliance as a checkbox. Improvement as a system.

Different brands require different due diligence information. Convergence matters. Initiatives like SLCP reduce duplication. But the deeper shift required is systems thinking.

We cannot solve volatility with isolated factory-level fixes.

We must examine algorithms that drive over-consumption. We must question purchasing models that reward speed over stability. We must ensure innovation in fashion does not generate pressures that workers are expected to absorb.

The best early warning system

The most resonant line of the Forum?

The best early warning system is Worker Voice.

Not because it is trendy.

Not because it sounds progressive.

But because it works.

When workers have safe channels to share concerns, patterns emerge early. Excessive overtime. Delayed payments. Unsafe conditions. Retaliation fears. Purchasing pressures.

Worker voice monitoring gives companies visibility beyond dashboards and disclosures. It connects due diligence to reality.

And as mandatory human rights due diligence expands across the EU and beyond, companies will need more than policies. They will need proof of process. Proof of engagement. Proof that their human rights framework is alive.

So what now?

The OECD Forum did not offer easy answers. It offered clarity.

Resilience in the supply chain is not built through cost-cutting alone.

Compliance is not achieved through audits alone.

Trust is not created through statements alone.

Resilience is built when wages are protected during shocks.

Compliance is strengthened when purchasing practices are monitored.

Trust grows when workers are heard.

Crisis will remain constant.

The question is whether our due diligence systems are dynamic enough to respond.

If we want a race to the top, we need shared responsibility across brands, suppliers, governments and workers. We need stakeholder engagement that redistributes power, not just information.

And we need to remember: the worker is not the shock absorber of the global economy.

If our human rights framework does not protect them when the system is under strain, then it is not a framework. It is a facade.

The future of mandatory human rights due diligence in the EU will not be defined by the number of policies written. It will be defined by whether workers feel the difference.

That is the real benchmark.

And that is the work ahead.