Governments are increasingly introducing binding and non-binding policy measures to promote responsible due diligence practices. Many of these share the core principle that businesses should look beyond the remit of what they can control, to social and/or environmental impacts connected to their supply chains and business relationships. This comparative mapping of 21 legislative measures demonstrates that, despite differences in scope, legal form and enforcement models, most instruments draw on a common conceptual foundation that is grounded in international standards and anchored around a core process of identifying, preventing and mitigating adverse impacts. These convergences provide a common architecture or framework that can be jointly refined and built on as governments develop interpretative guidance and support measures, and build capacity, including among supervisory authorities.
At the same time, the mapping highlights material divergences that can carry important implications for regulatory effectiveness and compliance. Differences in scope, due diligence expectations, liability regimes and enforcement mechanisms create a somewhat fragmented landscape that poses challenges both for public authorities tasked with oversight and companies operating across jurisdictions and business partners, particularly SMEs.
Many divergences are not merely technical but reflect distinct legal traditions, political compromises and regulatory philosophies. Even where legislative texts differ, however, building a common understanding around shared due diligence concepts and terminology (such as the risk-based approach, stakeholder engagement, and effective prevention and mitigation practices) can significantly reduce fragmentation. Governments can co‑ordinate on joint interpretative materials, practical guidance, tools and capacity-building initiatives for business and enforcement authorities. Identifying and building on synergies can also enhance opportunities for co‑ordination and peer learning around other support measures (such as common tools and standards for data exchange and collection along supply chains and/or data interoperability or centralised hubs for risk information). This is explored further in the accompanying paper: Reporting requirements in social and environmental due diligence legislation (OECD, 2026[1]).
As jurisdictions move from legislative adoption to implementation and enforcement, policy co‑operation and dialogue will be a critical part of increasing legal certainty, reducing complexity, and promoting effective and streamlined uptake and enforcement. Against this backdrop, the OECD Inclusive Platform on Due Diligence Policy Co‑operation offers an important space for dialogue and exchange. While this paper focusses on legislation, policy co‑operation around synergies and differences will also be important to consider across non-binding policy measures. A forthcoming online policy mapping visual and further discussions as part of the Platform will build on these findings and address opportunities for co‑operation and/or interoperability across both non-binding and binding measures.