Regulation (EU) 2024/3015 · In force Dec 2024 · Applies Dec 2027
EU Forced Labour Regulation Readiness & Investigation Preparedness
A structured due diligence assessment tool for companies placing products on the EU market. Identify supply chain forced labour risks, close your evidence gaps, and build the documentary record that matters when a complaint is filed — before it arrives.
New here? Run a demo scenario first to see what the tool assesses and how the gap analysis reads. Two scenarios: a prepared company and an unprepared one.
What is this tool, and who is it for?
Regulation (EU) 2024/3015 prohibits the placing, making available, or export of products made with forced labour on the EU market. It applies to every economic operator — from multinationals to SMEs — placing products on the EU market from 14 December 2027. Unlike earlier ESG frameworks, this regulation carries real enforcement consequences: a competent authority can require withdrawal of your products from the market and prohibit their re-import.
This tool is designed for three distinct users within a single organisation, all of whom need to engage with EUFLR compliance but for different reasons:
Legal & Compliance
Understand your EUFLR obligations precisely. Map evidence gaps to specific regulatory articles. Prepare for the 30-working-day preliminary assessment response window. Build and maintain the evidence log that protects the company if a complaint is filed.
Sustainability & Procurement
Conduct systematic, ILO-indicator-structured supply chain due diligence. Map forced labour risks to your specific commodity-country combinations. Identify where your monitoring and audit processes have gaps. Build the remediation roadmap. Credit existing certifications as evidence.
Board & C-Suite
Understand the regulatory exposure in plain terms. Receive a prioritised gap analysis that distinguishes critical investigation-triggering failures from good-practice aspirations. Export a board-ready report. Know what a complaint scenario looks like for your highest-risk supply chain today.
ℹ
This tool does not certify compliance
It does not tell you your products are free of forced labour. It does not replace legal advice. It assesses your processes for managing forced labour risk — not supplier conduct directly. What it produces is a structured, timestamped record of your due diligence that is the most defensible asset you can have if a competent authority comes knocking.
How the tool is structured
Four sequential stages, plus two standalone tools accessible at any time. You do not need to complete the tool in a single session — your answers are preserved within the browser session. For a first run, allow approximately 4–6 hours distributed across sustainability, legal, and procurement functions.
Stage 1
Company Profiling
Enter your sector, size, sourcing countries, and commodity profile. The tool auto-generates a preliminary risk heat map showing your highest-risk commodity-country combinations against ILO and US DOL data, flags any state-imposed forced labour geographies, and determines which EUFLR and CSDDD provisions apply to your organisation.
~15
data points
30–45 min
Stage 2
Due Diligence Assessment
Eight structured modules covering all 11 ILO forced labour indicators by supply chain phase. Each question is tagged to its EUFLR article, ILO indicator, and compliance tier (hard floor vs good practice ceiling). Questions include detailed practitioner guidance. Your Stage 1 risk profile determines which module questions are most critical — high-risk commodity-country combinations trigger deeper question sets.
Auto-generated as you complete modules. A ranked gap table distinguishes critical gaps (direct investigation exposure, hard EUFLR compliance floor) from high priority (significant due diligence weaknesses) and medium priority (good practice gaps). Each gap generates a specific remediation action with minimum adequate response, better practice pathway, effort rating, and indicative timeline.
Auto
generated
0 min extra
Stage 4
Evidence Log
A structured, timestamped record of every due diligence activity — audits, risk assessments, policy reviews, training, corrective actions. Each entry is mapped to the EUFLR article and ILO indicators it evidences. Designed specifically for the preliminary assessment response window. Also generates an investigation scenario simulation showing what a competent authority would find in your highest-risk supply chain today.
Ongoing
maintenance
15 min / entry
Standalone Tool
Complaint Response
Accessible at any time — no need to complete Stages 1–4 first. Enter the date a complaint or preliminary assessment request was received, the implicated product and country, and the alleged ILO indicators. Generates a day-by-day 30-working-day response plan, a live countdown to the submission deadline, and an evidence triage showing what you can currently demonstrate versus where your gaps are.
30
working days
use any time
What does the regulation actually require?
The Core Prohibition
Article 3 of Regulation (EU) 2024/3015 prohibits placing products made with forced labour on the EU market, making them available, or exporting them. The definition of forced labour is adopted from ILO Convention No. 29 (1930): work exacted under menace of penalty from someone who has not offered themselves voluntarily. Both elements must be present simultaneously.
The Due Diligence Standard
The regulation does not prescribe a specific due diligence methodology. Article 8 states that where a company has carried out due diligence in accordance with applicable Union law or international standards, competent authorities must take this into account. Commission implementation guidelines (due 14 June 2026) will define what "adequate" looks like. Until then, this tool uses the OECD 6-step framework and ILO 11 indicator structure as the best available proxy.
The regulation also incorporates worst-form child labour (ILO C182) within its scope via Recital 4. The precise legal relationship between child labour and forced labour — and where the ILO draws the line — is explained in full in the Definitions section.
Regulatory Timeline Key Dates
13 December 2024
Regulation Enters Into Force
Regulation (EU) 2024/3015 published and in force. Three-year implementation period begins. Companies should have begun risk profiling and governance work immediately.
14 December 2025
Member State Competent Authorities Designated
All 27 member states required to designate and notify competent authorities. These differ by member state and may differ by product category. Identify yours now — listed on the Forced Labour Single Portal.
Now — 14 June 2026
Commission Guidelines & Portal Launch Pending
Commission publishes implementation guidelines covering due diligence standards, risk indicators, and best practices. Forced Labour Single Portal and risk database launch simultaneously. This tool updates on publication. Companies should be in active assessment now — do not wait for guidelines to begin.
14 December 2026
Member State Penalty Frameworks Established
All member states notify the Commission of national penalty frameworks. Penalties must be effective, proportionate, and dissuasive. Wide variance expected across jurisdictions — monitor your primary member states.
14 December 2027
Regulation Fully Applicable — Hard Deadline
Prohibition on placing, making available, or exporting products made with forced labour takes full effect. Competent authorities may initiate investigations. Product withdrawal and import ban orders become available. All due diligence must be operational and documented by this date. Do not treat this as a planning horizon — building audit programmes, supply chain mapping, and evidence logs from scratch takes 18–24 months.
Third-Party Certifications — What They Do and Do Not Cover Important
Major certification and audit schemes can contribute to your EUFLR due diligence as evidence of specific process elements — but none is sufficient on its own. The tool credits certifications as evidence inputs against the specific ILO indicators they cover. Full details on the Methodology page.
Fairtrade International
Covers: minimum price and premium, child labour at smallholder level, dedicated hired labour standards (freedom of association, wages, working conditions). Strongest on economic standards and cooperative governance. Limited on recruitment-phase indicators, migrant worker debt bondage, and Tier 2+ supply chain.
Covers: environmental and social standards including some forced labour and human rights provisions. Worker voice mechanisms included but inconsistently verified. Known limitation: the 2020 standard revision weakened some earlier labour requirements. Does not constitute adequate EUFLR evidence for worst-form child labour or debt bondage without independent verification. UTZ no longer exists as a standalone scheme — transition to RA certification completed 2023.
SMETA / Sedex / BSCI
Covers: working conditions, health and safety, wages. Known limitation: document-review methodology consistently misses forced labour indicators that require worker interviews to detect.
RBA / Responsible Business Alliance
Covers: recruitment fees, document retention, working hours, wages. Strong in electronics sector. VAP audit includes worker interviews. Credible evidence for Modules C and D.
RSPO / FSC / PEFC
Covers: labour rights as a component of environmental certification. Useful as risk management evidence for Module B supply chain mapping, not as forced labour-specific audit.
Better Cotton Initiative / CanopyStyle
Covers: cotton origin standards including some labour provisions. Does not extend to polyester blends or synthetic fibres. Not sufficient alone for Xinjiang or Turkmenistan risk.
Amfori BSCI / SA8000
SA8000 is stronger on worker rights than most — includes grievance mechanisms and management systems. Useful for Module E evidence. Still document-heavy; worker interview quality varies by auditor.
Critical limitation across all schemes: No current certification scheme provides reliable coverage of state-imposed forced labour contexts (Xinjiang, Turkmenistan) where auditor access is restricted and worker testimony cannot be obtained freely. For these geographies, enhanced traceability to raw material origin and independent civil society verification are required — certification provides no material evidence.
Reference pages available in sidebar:
Demo Mode
Explore with a Sample Company
Select one of two fictional companies below to see how the tool behaves with a realistic pre-populated assessment. All data is illustrative. Demo mode does not overwrite any assessment you have already started — use the Reset button in either scenario to clear it.
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How demo mode works
Clicking "Load Demo" pre-populates Stage 1 and Stage 2 answers with realistic data for the selected company profile, then takes you directly to the Gap Analysis to see the output. The assessment reflects a company that has done some sustainability work but has not yet approached it specifically through the EUFLR lens — which is representative of most companies at this stage of preparation.
Scenario A — Large Enterprise
Meridian Foods Group BV
Fictitious · Food & Beverage · Netherlands
Sector
Food & Beverage processing
Turnover
€2.4 billion
Employees
8,200 (group)
EU Operations
NL, DE, FR, BE
Commodities & Sourcing Origins
Cocoa — Côte d'Ivoire, GhanaHIGH + Child Labour
Coffee — Ethiopia, ColombiaMEDIUM
Seafood — Thailand, IndonesiaHIGH
Pre-Assessment Situation
Has a CSR policy and a supplier code of conduct. Is Rainforest Alliance certified for cocoa. Has conducted SMETA audits at Tier 1. Has never mapped beyond Tier 1. No worker-interview-based audits. No grievance mechanism in supplier worker languages. No investigation readiness plan. CSDDD likely in scope.
5
Critical
7
High
6
Present
Scenario B — SME
Aldgate Apparel Ltd
Fictitious · Fashion Retail · United Kingdom / EU
Sector
Apparel & Footwear
Turnover
€38 million
Employees
145
EU Operations
IE, NL
Commodities & Sourcing Origins
Garments — Bangladesh, IndiaMEDIUM-HIGH
Cotton fibres — India, TurkeyMEDIUM
Pre-Assessment Situation
Small team — one sustainability manager alongside other responsibilities. Has a basic supplier questionnaire. Relies on customer-initiated audits shared by suppliers. No standalone forced labour policy. No supply chain mapping. No grievance mechanism. Has heard of EUFLR but has not yet assessed what it requires. CSDDD not in scope.
7
Critical
8
High
2
Present
Note: These scenarios are deliberately representative rather than worst-case or best-case. Both companies have done some work; neither has approached EUFLR systematically. The gap profiles reflect realistic findings for companies at this stage of preparation — Meridian somewhat further along due to greater resource; Aldgate earlier in the journey but with proportionate expectations under the SME pathway.
Bibliography
Sources, Legal Instruments & Scholarly Literature
Every factual claim, risk rating, legal classification, structural driver description, and remediation recommendation in this tool is traceable to one or more of the following sources. Where the ILO draws distinctions — particularly on child labour versus forced labour — those distinctions are documented here with the specific instruments that establish them.
I. Primary Legal Instruments
The tool is built on these instruments. All assessment questions are tagged to the relevant article or provision.
Foundational Definition
ILO Convention No. 29
Forced Labour Convention, 1930
Provides the definition of forced labour adopted verbatim by Regulation (EU) 2024/3015: work exacted under menace of penalty without voluntary consent. Article 2(1). Both elements — involuntariness and menace of penalty — must be present simultaneously. This instrument is the basis of the C29/C138/C182 distinction explained throughout the child labour sections. The 2014 Protocol to C29 adds obligations on prevention, protection, compensation, and remediation, and has been ratified by all EU member states.
Abolition Standard
ILO Convention No. 105
Abolition of Forced Labour Convention, 1957
Prohibits forced labour used as political coercion, economic development, labour discipline, punishment for participation in strikes, or racial, social, national, or religious discrimination. Extends the C29 prohibition to state-imposed contexts. Relevant to the Module F state-imposed forced labour questions and the Xinjiang and Turkmenistan risk classifications.
Child Labour — Minimum Age
ILO Convention No. 138
Minimum Age Convention, 1973
This is the instrument that explains why not all child labour is forced labour. C138 prohibits employment below minimum age (15 general; 13 light work; 18 hazardous) on developmental and educational grounds — independently of coercion. A child in light family work with no menace of penalty is in C138 child labour but does not satisfy C29 forced labour. The ILO maintains this distinction deliberately because the required responses differ: C29 requires immediate cessation and prosecution; C138 requires phased elimination with income support and schooling access. Conflating them leads to harmful remediation. C138 is within CSDDD scope but not directly within EUFLR scope.
Child Labour — Worst Forms
ILO Convention No. 182
Worst Forms of Child Labour Convention, 1999
The bridge between child labour and forced labour incorporated by EUFLR. Article 3(a) defines the worst forms to include: all forms of slavery and practices similar to slavery, expressly named as including "forced or compulsory labour, including the forced recruitment of children for use in armed conflict." Article 3(b): trafficking. Article 3(c): use of children in illicit activities. Article 3(d): hazardous work likely to harm health, safety, or morals. Worst forms satisfy the C29 elements because the circumstances themselves (debt bondage, coercion, trafficking) supply both involuntariness and menace of penalty. EUFLR Recital 4 references C182, making worst-form child labour actionable under EUFLR without a separate legal basis. Ratified by 187 ILO member states — the most rapidly ratified ILO convention in history.
The Regulation
Regulation (EU) 2024/3015
EU Forced Labour Regulation, December 2024
The instrument this entire tool is designed around. Key provisions: Article 3 (prohibition on placing, making available, and exporting products made with forced labour); Article 8 (due diligence as a factor in investigation decisions); Article 17 (preliminary assessment, 30-working-day response window); Recital 4 (incorporation of C29, C105, C182); Recital 17 (SME proportionality); Recital 18 (state-imposed forced labour as distinct category). Commission implementation guidelines and the Forced Labour Single Portal are both due 14 June 2026. This tool will update to reflect the guidelines on publication.
HRDD Foundation
UN Guiding Principles on Business and Human Rights
Ruggie, 2011. Endorsed by UN Human Rights Council Resolution 17/4.
The foundational human rights due diligence framework that underlies OECD guidance, CSDDD, and the Shift Project methodology used throughout this tool. The three-pillar structure (Protect, Respect, Remedy) and the "know and show" standard for due diligence inform the evidence log design and the distinction between identifying risks and demonstrating that a company has acted on them. Principle 13 (responsibility to respect) and Principle 17 (HRDD process) are directly relevant to the EUFLR due diligence standard.
II. ILO Operational & Technical Documents
These documents translate the legal instruments into operational practice. They are the primary source for the 11 indicators, the child labour/forced labour distinction, and the quantitative claims throughout the tool.
11 Indicators — Primary Source
ILO Indicators of Forced Labour
ILO Special Action Programme to Combat Forced Labour, 2012. Revised November 2025.
The source document for the 11 forced labour indicators that structure Modules B and C of this tool. Defines each indicator operationally with examples of how it manifests in practice, organised by supply chain phase (recruitment, employment, exit). Also the source for the child labour distinction: the handbook explicitly states that the C29 and C138 frameworks operate separately, and that non-worst-form child labour does not automatically constitute forced labour. The 2025 revision updated Indicators 1 (Abuse of Vulnerability) and 3 (Restriction of Movement) to reflect digital surveillance and state-imposed contexts. All module questions in Stage 2 are tagged to the relevant indicator number from this document.
Child Labour Methodology
Hard to See, Harder to Count
ILO Special Action Programme to Combat Forced Labour. Survey guidelines to estimate forced labour of adults and children, 2012. Updated 2024.
The ILO's methodological guidance for surveys measuring forced labour prevalence. Critical to the child labour discussion: this document sets out the ILO position that children in situations meeting C182 worst forms are presumed to satisfy the C29 elements, but that children in other work situations require case-by-case analysis of involuntariness and menace of penalty — meaning non-worst-form child labour is not presumptively forced labour. This is the primary reference for the legal analysis in the child labour section of the Overview page and the Methodology page.
Quantitative Estimates
Global Estimates of Modern Slavery
ILO and Walk Free Foundation, 2022. Updated 2024.
Source for all quantitative claims in this tool relating to global forced labour prevalence: 50 million people in modern slavery (28 million in forced labour); 29 million of those are women or girls; migrants face approximately three times the forced labour risk of non-migrants. These estimates are produced jointly by the ILO and Walk Free Foundation using a methodology combining national household surveys, literature review, and statistical modelling. They are the most methodologically rigorous available and are cited by the EUFLR impact assessment. The figures inform the structural drivers section (gender driver, migration driver) and the sector-level risk discussions.
Business Guidance
Combating Forced Labour: A Handbook for Employers and Business
ILO Special Action Programme to Combat Forced Labour, 2015. 2nd edition.
The ILO's practical guidance for businesses on identifying, preventing, and responding to forced labour in operations and supply chains. Bridges the legal framework and operational practice. Source for the supply chain phase structure (recruitment, employment, exit) used throughout Module C, and for the guidance notes explaining what each indicator looks like in practice. The minimum adequate response actions in the Stage 3 remediation roadmap are grounded in this document's recommendations.
Child Labour Remediation
Child Labour Monitoring and Remediation Systems (CLMRS)
ILO IPEC+ and International Cocoa Initiative. Operational guidance, multiple editions.
The primary framework for child labour monitoring and remediation in agricultural supply chains, developed for cocoa but applicable broadly. CLMRS is the source for the C9 question's guidance on structural remediation — the argument that removal of children from work without income replacement is counterproductive, and that remediation must address the structural drivers (poverty, school access, household debt). Also the source for the recommendation to use school enrolment data as a proxy indicator in cocoa supply chain monitoring (C8 guidance).
Cocoa Quantitative Data
Child Labour in the Cocoa Sector
ILO and NORC at the University of Chicago. Survey of child labour in Côte d'Ivoire and Ghana, multiple editions (2020, 2023).
Source for the quantitative child labour claims in the cocoa risk data: approximately 1.56 million children in child labour in cocoa supply chains in Ghana and Côte d'Ivoire combined (2020 estimate; 2023 data showed modest decline). These are the most methodologically robust available estimates, commissioned by the US Department of Labor. They inform the Stage 1 risk heat map flags for cocoa origins and the methodology page commodity tier table.
III. Due Diligence Frameworks
The process architecture of the tool — its eight-module structure, question sequencing, and remediation logic — is grounded in these frameworks.
Process Standard
OECD Due Diligence Guidance for Responsible Business Conduct
OECD, 2018.
The six-step due diligence process framework that both EUFLR and CSDDD reference, and which provides the backbone of this tool's module architecture. Step 1 (Embed) = Module A; Step 2 (Identify and Assess) = Modules B and C; Step 3 (Cease, Prevent, Mitigate) = Modules D, E, F; Step 4 (Track) = Module G; Step 5 (Communicate) = Stage 4; Step 6 (Remedy) = Module G. The B5 question draws directly on the Step 2 "likelihood and severity" analysis requirement, which the OECD guidance specifies must engage with operating context and structural factors — not only commodity-country risk lists.
Minerals — Sector Specific
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
OECD, 4th edition, 2016.
Source for cobalt and electronics risk data methodology, and for the Module F state-imposed forced labour framework in mining contexts. The five-step model in this guidance (establish management systems, identify and assess risk, design and implement response, carry out independent third-party audit, report on DD) maps directly onto Modules D and F for minerals supply chains. The ICGLR Regional Certification Mechanism referenced in the cobalt risk data is grounded in this guidance.
HRDD Methodology
UN Guiding Principles Reporting Framework
Shift Project and Mazars LLP, 2015.
Provides the operational HRDD methodology that bridges the UNGPs and company reporting practice. Source for the "lean in not walk away" principle referenced in the remediation guidance for high-risk sourcing contexts — the argument that exiting high-risk origins abandons the most vulnerable workers rather than protecting them. Also source for the concept of "severity" (scale, scope, irremediability) used to classify critical versus high versus medium priority gaps in Stage 3.
Living Income & FL Risk
Technical Guidance on Living Income and Forced Labour Risk in Agricultural Supply Chains
LICoP (Living Income Community of Practice) and Shift Project, 2025/2026. Note: consultation draft / not yet formally published as of March 2026. Treat as working document; verify current publication status before citing in a regulatory proceeding.
The document reviewed at the outset of this project. Establishes the link between household income below a living reference price and structural vulnerability to forced labour — specifically debt bondage (ILO Indicator 9) and deceptive recruitment (Indicator 2) — in agricultural supply chains. Source for the poverty driver in the structural drivers section, and for the C9 question's guidance on income support as essential to child labour remediation. Developed under CSDDD auspices but the income insufficiency framework is directly relevant as a structural risk indicator under EUFLR.
IV. Scholarly Literature
The structural drivers section, in particular, draws on academic literature that goes beyond regulatory frameworks to explain why forced labour occurs where it does.
Structural Model
Disposable People: New Slavery in the Global Economy
Bales, Kevin. University of California Press, 1999. Updated 2012.
Establishes the foundational structural model of modern slavery: high population pressure + low value of individuals + availability of violence = conditions for forced labour. Source for the poverty driver argument — Bales demonstrates that forced labour is not primarily a function of criminal opportunism but of structural economic conditions that make certain populations disposable. The insight that poverty is a structural driver (not merely a correlate) of forced labour informs the B5 question and the structural drivers section of the methodology page.
Debt Bondage Mechanism
Bonded Labor: Tackling the System of Slavery in South Asia
Kara, Siddharth. Columbia University Press, 2012.
The most detailed empirical study of the debt bondage mechanism across South Asia (India, Nepal, Bangladesh, Pakistan). Demonstrates that debt bondage consistently originates in a household financial crisis (medical emergency, dowry, crop failure) that cannot be resolved from income alone — meaning income insufficiency below a living threshold is the primary entry point. Source for the "income insufficiency as primary predictor" claim in the poverty driver, and for the argument in C9 guidance that child labour remediation without income support fails. Also source for Indicator 9 (Debt Bondage) operational descriptions in Module C.
Buyer Responsibility
"Modern Slavery as a Management Practice: Exploring the Conditions and Capabilities for Human Exploitation"
Crane, Andrew, LeBaron, Genevieve, Soundararajan, Vivek et al. Academy of Management Review, 2019.
The key academic source for the argument that modern slavery in supply chains is not primarily a governance failure in producing countries but a structural outcome of buyer purchasing practices. The paper identifies specific management practices that transfer cost and risk downstream until workers absorb them through coerced or unpaid labour: below-cost pricing, unrealistic lead times, volume volatility, long payment terms. This argument underpins Driver 6 (Buyer Business Model) in the structural drivers section, and the Module A5 question asking whether due diligence findings are integrated into procurement decisions.
Regulatory Failure Analysis
Combating Modern Slavery: Why Labour Governance is Failing and What We Can Do About It
LeBaron, Genevieve. Polity Press, 2021.
Analyses why existing supply chain governance mechanisms (audit regimes, certification schemes, voluntary codes) consistently fail to eliminate forced labour, and why weak rule of law is a structural enabler. Source for Driver 5 (Weak Rule of Law) arguments, and for the certification limitation notes in the Methodology page — particularly the argument that document-review audit methodologies (SMETA standard) miss the indicators that require worker interviews to detect.
V. Sector Data Sources & Risk Databases
Stage 1 risk data and commodity-country risk flags draw on these sources. The EUFLR Portal risk database (due June 2026) will supersede several of these as the authoritative EU reference on entry into operation.
Commodity-Country Risk
List of Goods Produced by Child Labor or Forced Labor
US Department of Labor, Bureau of International Labor Affairs (ILAB). Current edition.
The most comprehensive publicly available commodity-country forced labour risk list: 159 goods from 77 countries as of the current edition. Used as Data Layer 2 in the Stage 1 risk heat map. A commodity-country combination appearing on this list triggers elevated risk classification. The list is maintained by the US Department of Labor and updated periodically based on research conducted under the Trade and Development Act.
State-Imposed FL
UFLPA Entity List
US Customs and Border Protection, under the Uyghur Forced Labor Prevention Act (P.L. 117-78). Maintained continuously.
The US government's list of entities in Xinjiang or working with the Xinjiang government whose products are subject to a rebuttable presumption of forced labour under the UFLPA. Source for the Xinjiang-specific state-imposed forced labour flags in Stage 1 and Module F. Referenced in the Module H5 database monitoring question. While a US instrument, it is the best available current proxy for EUFLR purposes pending the June 2026 Portal risk database launch.
Vulnerability Index
Global Slavery Index
Walk Free Foundation, 2023.
Country-level vulnerability scores across five dimensions: government response, civil and political rights, refugee flows, access to social protection, and conflict/instability. Source for the Walk Free Vulnerability Model reference in Driver 5 (Weak Rule of Law) and in the B5 question guidance. Also contributes to Stage 1 country-level risk scoring for geographies not already flagged by ILO or ILAB data. The quantitative modern slavery estimates in the Index draw on the same ILO/Walk Free methodology as the Global Estimates publication above.
Garments Data
ILO Better Work Programme Country Reports
ILO and International Finance Corporation. Published annually for Bangladesh, Cambodia, Ethiopia, Haiti, Indonesia, Jordan, Myanmar, Nicaragua, Vietnam.
Factory-level compliance data from the garment sector in programme countries. Source for Bangladesh and Southeast Asian garment sector risk characterisations in the Stage 1 risk data and Methodology page commodity tier table. Better Work reports include indicators directly corresponding to several ILO forced labour indicators — freedom of association, working hours, wages — and are among the few data sources with systematic worker interview methodology at scale.
Tool Version & Update Obligations
This tool was last substantively updated in March 2026. It incorporates the ILO Forced Labour Indicators as revised in November 2025 and the LICoP/Shift Technical Guidance published in early 2026. Three mandatory updates are scheduled: (1) on publication of Commission implementation guidelines (due 14 June 2026) — all questions tagged ⟳ Pending Guidelines will be reviewed and updated; (2) on launch of the Forced Labour Single Portal (due 14 June 2026) — Stage 1 risk data will incorporate the Portal risk database; (3) annually thereafter. Users should not rely on the tool in isolation for legal advice, and should verify that no subsequent updates have been issued before relying on any output for a regulatory proceeding.
A reference glossary for the legal and technical vocabulary used throughout this tool. Organised by framework. Use this during assessment if a term requires clarification, or as a primer before beginning Stage 1.
A. EUFLR Legal Terms Regulation (EU) 2024/3015
These terms carry specific legal meanings under the regulation. Where the regulation's language differs from everyday usage or from the vocabulary of related frameworks (CSDDD, UK MSA), the distinction is noted.
Forced Labour
Art. 2 EUFLR · ILO C29 Art. 2(1)
"All work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily."
Two elements must both be present simultaneously. Involuntariness: the worker did not freely consent, or consent was obtained through deception or coercion. Menace of penalty: any threatened consequence of sufficient gravity — this does not require physical violence; it includes threatened job loss, debt enforcement, document retention, confinement, or denunciation to authorities. Neither element alone is sufficient. A worker who freely chose difficult or poorly-paid work is not in forced labour. A worker threatened with violence but who genuinely volunteered is an edge case the ILO treats contextually. The 2014 Protocol to C29 adds obligations on prevention, protection, compensation, and access to remedies.
State-Imposed Forced Labour
Art. 2 & Recital 18 EUFLR · ILO C105
Forced labour imposed by state authorities — a distinct subcategory under EUFLR carrying heightened enforcement consequences. Distinguished from ordinary forced labour in two respects: (1) the coercing party is the state rather than a private employer, making individual worker agency and employer compliance measures largely irrelevant; (2) standard audit mechanisms are insufficient because auditor access is restricted and worker testimony cannot be obtained freely. EUFLR Recital 18 identifies state-imposed forced labour as warranting particular attention and states that due diligence in these contexts goes beyond what would be expected in ordinary supply chain contexts. Currently documented at industrial scale in: Xinjiang (cotton, polysilicon — state mobilisation of Uyghur labour); Turkmenistan (cotton harvest — state mobilisation of civil servants and students); North Korean labour exported to third countries. ILO Convention No. 105 (1957) prohibits use of forced labour as a political, economic, or social control instrument by states.
Economic Operator
Art. 2 EUFLR
Any natural or legal person who places or makes products available on the EU market or exports them — regardless of where in the supply chain they sit. This is a deliberately broad definition: it includes manufacturers, importers, distributors, retailers, and online platform operators. It does not mean only large companies. An SME importing finished goods from a third country is an economic operator under EUFLR. The regulation applies to the entity that makes the product available — not (only) to the entity that made it. This is distinct from CSDDD, which applies to the company's own operations and its direct and indirect business relationships, and which has explicit size thresholds. EUFLR has no size threshold in its base application, though Recital 17 introduces a proportionality principle for SMEs in how due diligence is assessed.
Placing on the Market
Art. 2 EUFLR
Making a product available for the first time on the EU market — specifically, the act of a manufacturer or importer who introduces a product into the EU distribution chain. Distinguished from "making available on the market" (any subsequent supply in the distribution chain, including retail). Both are covered by the prohibition in Article 3. The distinction matters for determining which economic operator bears primary regulatory responsibility — the first placer in the EU chain — though all subsequent distributors who "make available" are also in scope. Export is also covered: Article 3 prohibits export of products made with forced labour from the EU market as well as import.
Preliminary Assessment
Art. 17 EUFLR
The first formal stage of a competent authority investigation. The authority issues a request to the economic operator for information and documentation relevant to the alleged forced labour. The economic operator has 30 working days (approximately six calendar weeks) to respond. The authority then decides whether to open a full investigation. The due diligence carried out by the economic operator is a central consideration at this stage — Article 8 states explicitly that if adequate due diligence has been carried out, this weighs in the operator's favour. The Complaint Response tool (accessible from the sidebar at any time) is designed specifically for this 30-working-day window. Pre-complaint evidence — documentation dated before the complaint was filed — carries significantly more weight than post-complaint evidence in a preliminary assessment.
Competent Authority
Art. 11 EUFLR
The national authority designated by each member state to investigate and enforce the EUFLR prohibition. Each member state designates its own authority or authorities — these may differ by product sector. The Commission acts as competent authority for state-imposed forced labour cases (where the state is the coercing party), reflecting the political sensitivity of those investigations. Member state authorities were required to be designated and notified to the Commission by December 2025 — they are listed on the Forced Labour Single Portal (launching June 2026). The relevant authority for a given investigation is typically determined by where the product is first placed on the EU market or made available, which means a company operating in multiple member states may face multiple relevant authorities.
Due Diligence (EUFLR)
Art. 8 EUFLR · Recital 17
The EUFLR does not prescribe a specific due diligence standard or methodology. Article 8 states that where an economic operator has carried out due diligence with respect to forced labour "in accordance with applicable Union law or international standards," competent authorities shall take this into account as a factor weighing against investigation. The applicable standards are: OECD Due Diligence Guidance for Responsible Business Conduct (2018), the ILO Tripartite Declaration, and the UN Guiding Principles. Commission implementation guidelines (due June 2026) will define what "adequate" due diligence looks like and what evidentiary standard competent authorities should apply. Until those guidelines publish, this tool uses the regulation text, the OECD framework, and the ILO indicator structure as the best available proxy. Recital 17 establishes that due diligence requirements are proportionate to company size and resources — a principle this tool reflects in how it distinguishes minimum adequate response from better practice in Stage 3.
The ILO operates a framework of four conventions relevant to forced and child labour. Understanding how they relate to each other — and where their scope diverges — is essential for accurate risk assessment and the child labour analysis below.
C29 1930
Forced Labour Convention
Provides the foundational two-element definition (involuntariness + menace of penalty) adopted by EUFLR. Requires member states to suppress all forms of forced labour. Does not distinguish child from adult workers — applies to any person. The 2014 Protocol adds modern slavery, trafficking, and debt bondage obligations. EUFLR scope: primary instrument.
C105 1957
Abolition of Forced Labour Convention
Prohibits forced labour as a tool of political coercion, economic development, labour discipline, strike punishment, or discrimination. Adds state-as-coercer dimension absent from C29. Relevant to the Xinjiang and Turkmenistan state-imposed forced labour classifications in Module F. EUFLR scope: referenced via Recital 4.
C138 1973
Minimum Age Convention
Prohibits employment below minimum age on developmental and educational grounds — independently of coercion. Minimum age: 15 generally; 13 for light work; 18 for hazardous work; developing country flexibility provisions exist. This is the instrument that explains why not all child labour is forced labour. A child doing light work on a family farm below minimum age, with no menace of penalty, is in C138 child labour but does not satisfy C29. The required response differs accordingly (see child labour section below). CSDDD scope; not directly EUFLR scope.
C182 1999
Worst Forms of Child Labour Convention
Defines worst forms to include (Art. 3): (a) all forms of slavery and practices similar to slavery, expressly named as including "forced or compulsory labour"; (b) trafficking; (c) use in illicit activities; (d) hazardous work likely to harm health, safety, or morals. This is the bridge between child labour and forced labour. Worst forms satisfy C29 because the circumstances themselves — debt bondage, coercion, trafficking — supply both the involuntariness and menace of penalty elements without further analysis. EUFLR Recital 4 incorporates C182, making worst-form child labour directly actionable under the regulation. Ratified by 187 ILO member states — the fastest ratification of any ILO convention. EUFLR scope: incorporated via Recital 4.
The 11 ILO Forced Labour Indicators — Reference Definitions
Published by the ILO Special Action Programme to Combat Forced Labour (2012, revised November 2025). These indicators are signals that forced labour may be present — not legal elements of the definition. One strong indicator, or several weaker indicators together, may be sufficient to conclude forced labour is occurring. They are organised by supply chain phase.
1Abuse of vulnerabilityRecruitment
The worker is in a position of vulnerability that the employer exploits to recruit them into work they would not freely accept. Relevant factors: undocumented migration status, poverty, disability, addiction, displacement, discrimination. Primary pathway for child labour where the child's age and developmental dependence constitutes the vulnerability.
2DeceptionRecruitment
False promises about the nature, location, conditions, or pay of work used to recruit. Contract substitution on arrival. Falsification of documents. Particularly prevalent in cross-border migrant worker recruitment.
3Restriction of movementEmployment
Workers prevented from leaving the workplace, dormitory, or geographic area. Includes physical confinement, confiscation of transport, debt that makes departure economically impossible, and digital surveillance of movement. Updated in 2025 revision to include electronic monitoring.
4IsolationEmployment
Workers cut off from family, community, or legal support networks. Compound or plantation housing designed to prevent external contact. Communication monitoring or restriction. Heightens all other indicators by reducing the possibility of external intervention.
5Physical & sexual violenceEmployment
Actual or threatened physical violence, sexual violence, or psychological abuse as a means of controlling labour. Includes violence by employer, supervisor, security personnel, or other workers on behalf of management.
6Intimidation & threatsEmployment
Threats of dismissal, deportation, denunciation to authorities, or harm to the worker's family as a means of preventing them from leaving or complaining. Threats do not need to be carried out to constitute menace of penalty under C29.
7Retention of identity documentsEmployment
Passports, identity cards, work permits, or other documents held by the employer without the worker's free and informed consent. Effective restriction of movement even without physical confinement. Common in migrant worker contexts.
8Withholding of wagesEmployment
Non-payment, underpayment, irregular payment, or unlawful deductions from wages used as a means of retaining workers or creating debt. Includes wage theft, kickbacks to supervisors, and manipulated piece-rate calculations.
9Debt bondageEmployment
Workers trapped by debts they are unable to repay from wages — typically originating in recruitment fees, transportation costs, housing, food, or equipment charges. The debt is often manipulated to be unpayable. Primary mechanism linking poverty to forced labour in agricultural supply chains.
10Abusive working & living conditionsEmployment
Working or living conditions so severe that they constitute effective coercion — wages too low to cover subsistence costs; accommodation controlled by employer; safety conditions creating constant risk of serious harm. Includes hazardous child labour where conditions meet worst-form threshold.
11Excessive overtimeEmployment
Systematic requirement to work beyond legal limits, without consent, and under threat of penalty for refusal. Persistent in export-oriented manufacturing under buyer price and lead time pressure.
C. Child Labour — The Precise Legal Position The ILO Line Explained
The question "is all child labour forced labour?" has an answer that is precise, important, and frequently misunderstood — including in some regulatory compliance literature. The ILO's answer is no. But worst-form child labour is always forced labour. The distinction is not semantic: it determines which legal instrument applies, what the required response is, and whether immediate enforcement or structural remediation is the appropriate course of action.
The Two-Element Test Applied to Children
Element 1 — Involuntariness
ILO doctrine does not hold that children are categorically incapable of any consent for all purposes. What it holds is more specific: that in situations involving worst-form child labour — trafficking, debt bondage, coercion — the circumstances themselves negate any meaningful consent. For non-worst-form situations, the ILO applies a contextual analysis: a child working on a family farm, for example, is not presumed to have been coerced into it in the same way a trafficked child is. The presence of parental authority is not automatically equivalent to an employer's coercive power.
Element 2 — Menace of Penalty
This element must be assessed in each situation. A child doing light domestic work at home, or helping with a harvest without any threatened consequence for stopping, does not satisfy this element regardless of age. A child in debt bondage, or facing violence or deprivation if they refuse to work, clearly does. The ILO's Indicators of Forced Labour handbook (2012, revised 2025) explicitly states that non-worst-form child labour does not automatically constitute forced labour under C29, and must be assessed against both elements in context.
The Four Categories — Where the ILO Draws the Line
C182 Art. 3(a)&(b). Both C29 elements structurally satisfied — coercion and involuntariness are inherent to the situation, not incidental. Immediate cessation, law enforcement referral, and access to remedies required. EUFLR actionable via Recital 4.
C29 ✓ Forced Labour
C182 ✓ Worst Forms
EUFLR ✓ In Scope
Worst
Hazardous child labour under coercive conditions
C182 Art. 3(d). Children in hazardous work (mining, deep-sea fishing, toxic chemical exposure, heavy machinery) where they cannot freely leave. ILO Indicator 10 (abusive conditions) applies. Satisfies C29 where the conditions themselves constitute menace and the child's situation renders refusal practically impossible. EUFLR actionable. Examples: DRC cobalt artisanal mining, certain West African cocoa operations.
C29 ✓ Forced Labour
C182 ✓ Worst Forms
EUFLR ✓ In Scope
Standard
Hazardous child labour without coercive conditions
C182 Art. 3(d) applies. Hazardous work regardless of coercion. C29 assessment is contextual — if the child can freely leave but chooses not to due to poverty, the menace of penalty element requires analysis. Often a borderline case. In practice, hazardous conditions and coercive conditions co-occur frequently. Requires immediate withdrawal from the hazard.
C29 — Contextual
C182 ✓ Worst Forms
EUFLR — Contextual
C138
Non-hazardous work below minimum age, without coercion
C138 only. Light farm work, household tasks, family business assistance. Prohibited on developmental grounds regardless of conditions — but the menace of penalty element of C29 is absent, so this is not forced labour. The ILO explicitly preserves this distinction. Requires phased elimination with income support, school access, and household debt resolution — not immediate enforcement action. Abrupt withdrawal without addressing the income gap that drove the child's presence typically worsens outcomes.
C29 ✗ Not FL
C138 ✓ Child Labour
EUFLR ✗ Not Direct
Why the ILO Preserves This Distinction — The Policy Reason
The ILO maintains the C138/C29 distinction deliberately and documents it in its operational guidance (Indicators of Forced Labour, 2012; Hard to See, Harder to Count, 2012/2024). The policy reason: non-worst-form child labour in agricultural supply chains is overwhelmingly a symptom of household poverty below a living income threshold, not of employer criminality. The household cannot meet basic needs from adult income alone; the child's labour contribution is a coping mechanism. If a company responds to finding C138 child labour by immediately terminating the supplier — or a competent authority responds by ordering product withdrawal — the household loses income without the underlying poverty being addressed. Research across cocoa supply chains (ILO/NORC surveys, Chocolate Score Card data) consistently shows that abrupt supplier termination increases child labour in the same region as households find less visible alternatives. The CLMRS (Child Labour Monitoring and Remediation Systems) framework — developed by ILO IPEC+ and the International Cocoa Initiative — is built on this insight: effective remediation requires ongoing community monitoring, income support, school fee coverage, and farmer price improvement, coordinated over time. This is why the tool's C9 question asks whether the organisation has assessed the structural causes of child labour, and whether remediation goes beyond removal.
D. Supply Chain Terminology Industry Convention · Not EUFLR Terminology
Several terms used throughout this tool are industry convention rather than regulatory definitions. This matters because a legal argument framed in industry terms may not map cleanly onto what the regulation actually requires.
Due Diligence vs. Compliance
Conceptual distinction
Compliance asks: does the supplier meet a defined standard? It is binary, point-in-time, and produces a pass/fail result. Due diligence asks: what did the company do to identify, prevent, mitigate, and account for its impacts on human rights? It is process-oriented, continuous, and produces a documentary record rather than a certification. The EUFLR is a due diligence instrument: Article 8 makes clear that adequate due diligence is a factor in the competent authority's assessment, not a defence of certification or compliance. A company that has done extensive, documented due diligence but whose supply chain still contains forced labour is in a very different regulatory position from one that has done none. This distinction is why the Evidence Log (Stage 4) is as important as the gap assessment (Stage 3).
Traceability
Conceptual distinction
The ability to identify and follow the pathway of a product, ingredient, or material through the supply chain from origin to final product. Distinguished from supply chain mapping (knowing who your suppliers and sub-suppliers are) — traceability adds origin-specificity: not just "we source cotton from India" but "this fabric contains cotton from these specific farms in Gujarat." For forced labour purposes, traceability to raw material origin is the evidentiary standard required for state-imposed forced labour contexts (Xinjiang, Turkmenistan) because standard audit evidence is insufficient there. Mass-balance certification schemes (Better Cotton Initiative) provide blended origin claims that satisfy sustainability reporting but do not satisfy forced labour traceability requirements for SIFL-risk origins.
Leverage
OECD · Shift · UNGPs
The ability of a company to effect change in the practices of a supplier. Leverage is a function of purchasing volume, strategic importance of the relationship to the supplier, and the buyer's willingness to use commercial relationships to drive change. The OECD and Shift frameworks both identify leverage as a key determinant of what due diligence response is appropriate — a company with high leverage over a supplier has different obligations than one with negligible leverage (e.g. one of thousands of customers buying an undifferentiated commodity). Increasing leverage — through long-term purchase commitments, supplier development investment, collective action with other buyers — is itself a valid due diligence strategy rather than a precondition for it.
Specifications
Tool Specification Sheet
A structured technical reference for governance sign-off, procurement evaluation, or regulatory disclosure. States precisely what this tool covers, what it does not cover, how its data is sourced and maintained, and what update obligations apply. Where relevant, a competent authority reviewing your due diligence process may ask what tool or methodology underpinned your assessment — this page provides the answer.
Identity & Version
Tool Name
EUFLR Readiness & Investigation Preparedness Tool
Current Version
v0.9 — Pre-Guidelines Release
March 2026. Will advance to v1.0 on publication of Commission implementation guidelines (due 14 June 2026).
Last Substantive Update
March 2026
ILO Forced Labour Indicators revised November 2025 incorporated. LICoP/Shift Technical Guidance 2026 incorporated.
Primary Regulatory Instrument
Regulation (EU) 2024/3015
Entered into force 13 December 2024. Full application from 14 December 2027.
Format
Single-file HTML application
Runs entirely in-browser. No server-side processing. No data transmitted. Session state only — not persisted between sessions.
Intended Users
Legal, sustainability, procurement, board
Designed for cross-functional use. Distinct utility for each function — see user persona descriptions on Overview page.
Regulatory Coverage
This table states precisely which provisions of Regulation (EU) 2024/3015 are addressed by the tool, which adjacent instruments are covered, and which are out of scope.
Provision / Instrument
Status
Coverage Note
EUFLR Art. 3 — Prohibition
✓ Full
Core prohibition addressed throughout. All assessment modules structured around demonstrating what actions have been taken to prevent placing products made with forced labour on the market.
EUFLR Art. 8 — Due Diligence Factor
✓ Full
The tool is explicitly designed to generate the evidence base that Art. 8 requires. Module A–H structure maps to the due diligence steps competent authorities will evaluate.
Addressed by the Complaint Response standalone tool, which generates a day-by-day response plan and live countdown from the date of complaint receipt.
EUFLR Art. 11 — Competent Authorities
~ Partial
Tool identifies the authority designation framework and the Commission's role in SIFL cases. Does not maintain a live directory of member state authority designations — users should verify on the Forced Labour Single Portal (launching June 2026).
EUFLR Commission Implementation Guidelines
⟳ Pending
Due 14 June 2026. Questions tagged ⟳ in Stage 2 will be updated on publication. The tool will advance from v0.9 to v1.0 at that point. Sections likely to require update: Module A governance standard, Module D audit methodology, Module F SIFL procedure.
EUFLR Forced Labour Single Portal
⟳ Pending
Due 14 June 2026. Stage 1 risk heat map will be updated to incorporate the Portal risk database. Until then, US DOL ILAB List of Goods and UFLPA Entity List serve as proxies.
ILO C29 — Forced Labour Definition
✓ Full
The two-element definition (involuntariness + menace of penalty) is the basis of all 38 assessment questions and all risk classifications.
ILO C138 — Minimum Age (Child Labour)
~ Partial
Addressed in Module C (C8, C9) and in the Definitions page. Not directly within EUFLR scope, but within CSDDD scope and a structural risk indicator. Tool notes the C138/EUFLR distinction explicitly throughout.
ILO C182 — Worst Forms of Child Labour
✓ Full
Incorporated via EUFLR Recital 4. Addressed in Module C and throughout child labour sections of Overview, Methodology, and Definitions pages.
ILO C105 — Abolition of Forced Labour
✓ Full
State-imposed forced labour context addressed in Module F. Xinjiang, Turkmenistan, North Korean export labour flagged throughout Stage 1 risk data.
CSDDD — Corporate Sustainability Due Diligence
~ Partial
Where CSDDD obligations overlap with EUFLR (governance structure, supply chain mapping, grievance mechanisms), the tool notes the dual relevance. CSDDD-specific obligations (value chain partners, direct business relationships threshold, transition plans) not addressed. Separate CSDDD readiness assessment required for companies in scope.
UK Modern Slavery Act
↗ Ref
Referenced in Stage 1 company profile. Tool notes that MSA transparency statement obligations do not satisfy EUFLR due diligence standard — different purpose, different evidence threshold.
UFLPA — Uyghur Forced Labor Prevention Act (US)
↗ Ref
UFLPA Entity List used as a proxy data source for Xinjiang SIFL risk pending EUFLR Portal. Rebuttable presumption standard under UFLPA differs from EUFLR — compliance with one does not imply compliance with the other.
Assessment Structure & Question Inventory
38 assessment questions across 8 modules in Stage 2. Each question is tagged by compliance type and mapped to one or more ILO forced labour indicators and EUFLR articles.
Directly required by EUFLR text or OECD DD standard
17
Good Practice / Emerging Standard
Best practice; likely required under Commission guidelines
23
Country Risk Entries in Stage 1
Across 8 commodity categories
Data Sources & Version Dates
The Stage 1 risk heat map and all commodity-country risk flags draw on the following data sources. Version dates are stated so a user can identify when the underlying data was last refreshed.
ILO Forced Labour Indicators
November 2025
✓ Full
All 38 assessment questions in Stage 2 are structured around the revised 11 indicators. Revision updated Indicators 1 (Abuse of Vulnerability) and 3 (Restriction of Movement) to reflect digital surveillance.
ILO Global Estimates of Modern Slavery
2022 (updated 2024)
✓ Full
Source for all quantitative prevalence claims: 50m people in modern slavery, 28m in forced labour, 29m women/girls, 3× migrant risk. Next update expected 2026.
ILO / NORC Cocoa Child Labour Survey
2023
✓ Full
Source for ~1.56m children in child labour in Ghana and Côte d'Ivoire cocoa supply chains. 2023 data shows modest decline from 2020 peak.
US DOL ILAB List of Goods
Current edition (2024)
✓ Full
Stage 1 risk heat map Data Layer 2. 159 goods from 77 countries. Updated periodically — check ilab.dol.gov for currency.
UFLPA Entity List
Maintained continuously
✓ Full
State-imposed forced labour proxy for Xinjiang pending EUFLR Portal. Updated by US CBP on rolling basis. Check cbp.gov/uflpa for current list.
Walk Free Global Slavery Index
2023
✓ Full
Country vulnerability scoring used for rule-of-law risk driver in structural drivers section. Next edition expected 2025/2026.
ILO Better Work Country Reports
Various (2023–2024)
~ Partial
Garments sector data for Bangladesh, Cambodia, Indonesia, Vietnam, Jordan. Coverage limited to programme countries.
EUFLR Portal Risk Database
Not yet operational
⟳ Pending
Due June 2026. Will supersede ILAB list and UFLPA proxy as authoritative EU source. Stage 1 risk data will be updated on Portal launch.
Commission Implementation Guidelines
Not yet published
⟳ Pending
Due 14 June 2026. Will determine what adequate due diligence looks like under EUFLR. All questions tagged will be reviewed on publication.
US State Dept. TIP Report
Annual (June)
✓ In Use
Trafficking in Persons Report — annual country-level tier ratings (Tier 1 / 2 / 2WL / 3) for trafficking and forced labour government response. Authoritative cross-country governance benchmark. Informs country-level risk scoring in Stage 1 alongside ILAB and Walk Free.
ASPI Xinjiang Data Project
Ongoing
✓ In Use
Australian Strategic Policy Institute — facility and company mapping of Xinjiang forced labour in cotton and polysilicon supply chains. Referenced by US CBP and European Commission. Most rigorous independent evidence base for SIFL risk in these commodities. Used to inform Module F SIFL risk classifications.
Sheffield Hallam University — Supply Chain Research
2020–2023
✓ In Use
Sector-specific supply chain tracing reports on Xinjiang cotton (2020) and polysilicon (2021, 2023). Commissioned basis evidence used by multiple governments and the EU in their SIFL risk assessments. Most detailed available traceability analysis for these specific commodity-origin combinations.
Seafood Task Force / NOAA Fisheries
Annual
~ Partial
Seafood sector labour risk data, including vessel-level IUU fishing and forced labour overlap. Source for Thai and Indonesian fishing fleet risk characterisations in Stage 1. Coverage limited to Seafood Task Force programme countries.
Business & Human Rights Resource Centre
Ongoing
~ Reference
Company and sector tracking of human rights allegations including forced labour. Not a primary evidence source but useful for identifying emerging sector risks and company-specific allegations that may trigger investigation risk. Referenced in Module H5 monitoring guidance.
Explicit Scope Limitations
Stated clearly so there is no ambiguity about what the tool does and does not do. A user relying on this tool for a regulatory proceeding should read this section.
✗
Does not certify compliance
The tool assesses the existence and quality of processes — not whether your supply chain is free of forced labour. No tool, audit, or certification can make that claim. Forced labour is by definition hidden. What the tool evidences is that the required steps to identify and prevent it were taken.
✗
Does not assess specific suppliers
The tool assesses your organisation's processes for managing suppliers — not the conduct of any specific supplier. Findings are about your due diligence system, not about whether Supplier X is compliant.
✗
Does not constitute legal advice
The tool is an operational assessment aid. It is not a legal opinion on your EUFLR compliance position. Legal counsel should review any output used in a regulatory proceeding.
✗
Does not predict competent authority outcomes
The gap analysis and priority ratings reflect the tool's assessment of what is required under EUFLR and the OECD framework. They do not predict how a specific competent authority in a specific member state will assess a specific set of facts.
✗
Does not cover all CSDDD obligations
Where EUFLR and CSDDD overlap, the tool notes dual relevance. CSDDD-specific obligations — including value chain partner engagement obligations, transition plans, and the direct/indirect business relationship threshold — require separate assessment.
✗
Pre-guidelines release
This is version 0.9. Commission implementation guidelines (due 14 June 2026) will define what adequate due diligence looks like under EUFLR. Until those guidelines publish, this tool uses the regulation text, OECD framework, and ILO indicators as the best available proxy. Some question weightings and gap priorities may change on guidelines publication.
✗
Session-only data persistence
Assessment responses are held in browser session memory only and are not saved between sessions. Use the Export Report function (Stage 4) to preserve your assessment output before closing the browser.
Mandatory Update Schedule
Three scheduled updates are committed to. Users should verify the version date before relying on tool output for a compliance decision or regulatory proceeding.
Update 1
14 June 2026
Commission Guidelines
All 38 assessment questions reviewed against published guidelines. Questions tagged ⟳ updated or confirmed. Gap priority ratings recalibrated. Module A governance standard and Module D audit methodology sections most likely to require material change. Tool advances from v0.9 to v1.0.
Mandatory
Update 2
14 June 2026
Portal Risk Database
Stage 1 risk heat map updated to incorporate the Forced Labour Single Portal risk database as Data Layer 1 (superseding current ILAB proxy). Country and commodity risk entries reviewed and recategorised where Portal data differs from current classifications. Module H5 database monitoring question updated to include Portal monitoring workflow.
Mandatory
Update 3
Annual
From December 2026
Full annual review: ILAB list currency check; ILO Global Estimates update (expected 2026); Walk Free Index update; Better Work country report refresh; UFLPA Entity List material changes; any new Commission guidance, enforcement decisions, or member state authority guidance that affects question content or priority weightings.
Scheduled
Methodology & Data Sources
How the Assessment Works
The technical and regulatory foundations of this tool — what data it uses, what the assessment questions are based on, how the geographic and tier dimensions are captured, and how third-party certifications are integrated as evidence.
Regulatory & Framework Foundations
Primary Law
Regulation (EU) 2024/3015
The EUFLR itself. All module questions are tagged to specific articles. Hard compliance questions reflect the regulation text; good practice questions reflect what competent authorities are expected to weigh under the due diligence standard. Commission implementation guidelines (due June 2026) will refine this — the tool will update on publication.
Indicator Framework
ILO Forced Labour Indicators
The 11 forced labour indicators published by the International Labour Organisation — revised November 2025. These define what forced labour looks like operationally, phase by phase (recruitment, employment, exit). Every Module C question directly maps to one or more indicators. The revised 2025 version updated Indicator 3 (Restriction of Movement) and Indicator 1 (Abuse of Vulnerability) to reflect digital surveillance and state-imposed contexts.
Due Diligence Process
OECD DD Guidance (2018)
The OECD Due Diligence Guidance for Responsible Business Conduct provides the six-step process framework that EUFLR and CSDDD both reference. Steps 1–6 map directly to Modules A (Embed), B (Identify), C (Assess), D+E (Respond), F+G (Track), Stage 4 (Communicate). Each question is tagged to the relevant OECD step.
HRDD Methodology
Shift Project / UNGPs
The Shift Project's operationalisation of the UN Guiding Principles on Business and Human Rights provides practitioner guidance that sits between the regulatory text and implementation reality. The "lean in" principle (do not exit high-risk origins; this abandons the most vulnerable), worker voice standards, and leverage framework all inform the good practice ceiling in the assessment modules.
State-Imposed FL
UFLPA / OHCHR / ILO
The US Uyghur Forced Labor Prevention Act entity list, OHCHR reports on Xinjiang, ILO annual reports on Turkmenistan, and EEAS 2021 due diligence guidance inform the state-imposed forced labour risk flags in Stage 1. These are updated as new evidence is published. The EUFLR Portal risk database (due June 2026) will replace these as the primary reference once operational.
Risk Data Sources — Stage 1 Heat Map
The Stage 1 preliminary risk heat map cross-references your commodity-country profile against three data layers. This is a macro-level risk signal — it tells you where to look, not what you will find.
Data Layer 1
ILO Forced Labour Country Data
ILO convention ratification status, documented forced labour by country and sector, ILO Better Work country programmes, and ILO Global Estimates of Modern Slavery (2022, updated 2024).
Data Layer 2
US DOL List of Goods
The US Department of Labor List of Goods Produced by Child Labor or Forced Labor (ILAB) — 159 goods from 77 countries. A commodity-country combination on this list triggers an elevated risk rating in the Stage 1 map.
Data Layer 3
State-Imposed FL Evidence
UFLPA Entity List (US), OHCHR reports, ILO Turkmenistan documentation, academic and civil society documentation for known SIFL contexts. Highest-confidence risk signals in the dataset.
What the risk map does not do: It does not assess your specific suppliers. It does not access real-time data feeds. The EUFLR Portal risk database (due June 2026) will provide the authoritative EU risk signal — Stage 1 will update to incorporate Portal data on launch. Until then, the heat map uses the best publicly available proxy data. Treat it as a starting point for prioritisation, not a conclusion about your supply chain.
Geographic Dimension — How Countries Are Handled
Geography is the primary axis of forced labour risk — the same commodity carries very different risk profiles depending on origin country and region. The tool captures geography at three levels.
Level 1
State-Imposed FL Geographies
Specific regions where national governments compel citizens to work: Xinjiang Uyghur Autonomous Region (polysilicon, cotton), Turkmenistan (cotton harvest), North Korean labour deployed in third countries. These trigger Module F automatically and carry the highest investigation risk under EUFLR. Standard audit evidence is assessed as insufficient for these origins.
Level 2
Commodity-Country High Risk
Specific commodity-country combinations with documented forced labour (ILO/DOL/NGO evidence): DRC cobalt, Malaysia electronics (migrant workers), Bangladesh garments, Thailand seafood, Côte d'Ivoire cocoa. These generate HIGH risk cells in Stage 1 and prioritise Module C questions accordingly.
Level 3
Your Specific Sourcing Origins
You enter your specific sourcing countries in Stage 1. These are cross-referenced against Levels 1 and 2. If you source from a country not in the risk database, it appears as MEDIUM risk (unknown / unassessed) rather than LOW — the absence of documented forced labour does not mean its absence. The investigation scenario in Stage 4 is built around your specific highest-risk geography.
Coming in next version: Sub-national geographic risk (province/state level) for the highest-priority commodities — recognising that risk within a country is highly uneven (e.g. Sabah vs Peninsular Malaysia for palm oil; Sichuan vs Xinjiang for polysilicon).
Where in the Production Process Does the Risk Sit?
Every company's supply chain is different, and the point at which forced labour risk concentrates depends entirely on the specific commodity, its production process, and the country of origin. There is no universal taxonomy. The EUFLR does not ask "which tier?" — it asks where in this product's specific production process is forced labour most likely to occur, and whether your due diligence reaches that point. For cotton, that is typically the farm and gin. For electronics, it may be the polysilicon reduction furnace. For cocoa, the individual smallholder farm. For seafood, the fishing vessel. Your Stage 1 commodity and country selections will drive the risk profile for your specific supply chain — that is where this tool maps your exposure, not here.
Reference — Authoritative Risk Lists
The most comprehensive publicly available commodity-country forced labour risk lists are: the US Department of Labor ILAB List of Goods Produced by Child Labor or Forced Labor (159 goods, 77 countries — ilab.dol.gov); the US State Department Trafficking in Persons Report (annual country-tier ratings — state.gov/tip); and the EUFLR Forced Labour Single Portal risk database (due June 2026 — will become the authoritative EU reference on entry into operation). For Xinjiang-specific supply chain traceability, the ASPI Xinjiang Data Project and Sheffield Hallam University sector reports are the most rigorous independent evidence sources. None of these lists is exhaustive — documented forced labour risk extends across more than 159 goods, and the absence of a commodity from a published list does not constitute evidence that risk is absent.
When completing Stage 2 modules, you can note certifications and audit schemes as evidence against specific questions. The following maps certifications to the ILO indicators and EUFLR modules they provide evidence for — and their known limitations. Use this to credit your existing certifications appropriately, without overclaiming their scope.
Covers smallholder employment, not migrant recruitment phase. Price premium does not address debt bondage at intermediary level.
Rainforest Alliance / UTZ
Cocoa, coffee, tea, palm oil
8, 10, 11; some 1 (vulnerability assessment)
C, D
Farm-level audit quality highly variable. Migrant worker and recruitment indicators not systematically assessed. Does not cover upstream supply chain.
SMETA 4-Pillar (Sedex)
Cross-sector manufacturing
7, 8, 10, 11; some 3, 9
A, C, D
Document-review methodology. Consistently fails to detect indicators requiring worker interviews (2, 3, 4, 6, 7). Industry-wide acknowledged limitation. Only SMETA with worker interviews provides meaningful forced labour evidence.
RBA VAP (EICC)
Electronics, ICT hardware
2, 7, 8, 9, 10, 11
C, D, E
Strongest scheme for migrant worker recruitment indicators. Worker interviews included. Limited geographic reach — primarily Southeast Asia. Does not extend upstream to raw materials.
SA8000 (SAI)
Cross-sector
All 11 indicators (partial)
A, C, D, E
Strongest management system standard — includes worker committees and grievance. Implementation quality varies significantly by auditor. Expensive for smaller suppliers.
Better Cotton Initiative
Cotton
8, 10, 11; some child labour (1)
B, C
Mass balance traceability — not physical traceability to specific origin. Cannot demonstrate that your cotton is not from Xinjiang or Turkmenistan.
RSPO / ISCC
Palm oil, biofuels
8, 10; some 3 (freedom of movement)
B, C
Environmental certification with labour provisions. Not forced-labour-specific. Grievance mechanism coverage improving under RSPO Next standard.
OECD DD Guidance (Minerals)
Cobalt, tin, tungsten, gold
1, 4, 5, 8, 9, 10
B, C, F
Process standard, not an audit scheme — companies must implement it themselves. ICGLR certification partial geographic coverage. Artisanal mining remains structurally difficult.
Explicit limitation across all schemes for state-imposed FL: No current certification scheme provides reliable evidence for Xinjiang polysilicon, Xinjiang cotton, or Turkmenistan cotton. In these geographies, auditor access is restricted, worker testimony cannot be obtained freely, and government presence prevents independent verification. Only supply chain traceability to origin (DNA testing, isotope analysis, blockchain) and independent civil society reporting provide meaningful evidence. Certification in these contexts should not be cited as evidence in a EUFLR response.
Structural Drivers of Forced Labour — The Scholarly Framework
The ILO 11 forced labour indicators describe how forced labour manifests in a workplace — the observable signs that it is occurring. But they do not explain why it occurs where it does, or what conditions make some supply chain segments structurally prone to it while others are not. The academic and practitioner literature — including Siddharth Kara's work on bonded labour, Kevin Bales's structural model, the ILO's Global Estimates of Modern Slavery, Walk Free Foundation's Vulnerability Model, and Crane, LeBaron, Soundararajan et al. on modern slavery in global supply chains — converges on a consistent set of upstream structural drivers. Understanding these is essential for two reasons: they should inform how companies assess likelihood in their risk assessment (OECD Step 2), and they determine whether remediation will succeed or fail.
The tool's Stage 1 risk heat map captures the macro-level expression of some of these drivers (documented forced labour by commodity and geography). Module B asks whether your risk assessment has gone deeper, to evaluate structural factors for your specific supply chain segments. The table below explains what the literature says and what companies should be looking for.
Driver 1
Poverty & Income Insufficiency
The most robust predictor in the empirical literature. Workers below a living income threshold cannot afford to walk away from exploitative employment — the cost of exit (lost income, debt, displacement) exceeds the cost of staying. Kara's bonded labour research across South Asia and West Africa shows that debt bondage consistently originates in an initial financial crisis the worker cannot resolve from income alone. The ILO Global Estimates show that poverty is the single strongest predictor of forced labour prevalence across regions. The LICoP/Shift living income framework — designed for CSDDD — is directly relevant here as a risk indicator under EUFLR: a commodity-country combination where farm-gate prices consistently fall below a living reference price is a structurally high-risk environment for debt bondage (ILO Indicator 9) and deceptive recruitment (Indicator 2), regardless of what supplier audits show.
ILO Links
Indicators 2, 9
Driver 2
Migration & Displacement
Migrant workers — both international and internal — are disproportionately represented in forced labour populations across all sectors and geographies. The ILO estimates migrants face nearly three times the forced labour risk of non-migrants. The structural mechanisms are consistent: unfamiliar legal systems remove knowledge of rights; language barriers limit access to grievance mechanisms; social isolation removes external support networks; dependence on the employer for housing creates a power asymmetry that persists throughout employment. Displacement — whether from conflict, climate events, or economic shock — compounds this by removing even the option of return. Supply chain segments with high migrant worker concentrations (Malaysia electronics and construction; Gulf migrant domestic workers; Southeast Asian seafood vessels; UAE and Qatar across sectors) require migration-specific risk assessment, not just general working conditions audits.
ILO Links
Indicators 1, 2, 3, 4, 7, 9
Driver 3
Informality of Employment
Workers in informal labour arrangements — agricultural piece-workers, homeworkers, platform workers, domestic workers, artisanal miners — lack the legal protections, labour inspection coverage, and grievance access that formal employment provides. Informality is structurally connected to invisibility: informal workers do not appear in factory audits, payroll records, or social insurance systems. Crane et al. argue that the structure of global supply chains actively produces informality in their lower tiers by transferring cost pressure and risk downstream until it reaches workers who absorb it through unpaid labour and dangerous conditions. The CSDDD's explicit extension to self-employed workers reflects growing recognition of this. For EUFLR purposes, high informality in a supply chain tier is a structural risk multiplier — it reduces the likelihood that audit processes will detect forced labour even when it is present.
ILO Links
Indicators 1, 8, 10, 11
Driver 4
Gender & Intersecting Vulnerabilities
Women and girls are disproportionately represented in forced labour populations — the ILO estimates 29 million of the 50 million people in modern slavery are women or girls. The mechanisms are sector-specific: in agriculture, women typically have weaker land rights and less income control than men in the same household, making them more vulnerable to recruitment fraud; in garments, women constitute the large majority of the workforce in export processing zones where freedom of association is frequently restricted; in domestic work, the combination of private household employment and migration creates extreme isolation. The LICoP/Shift guidance notes that within smallholder cocoa farming, income typically flows to male household heads rather than female pickers — meaning even where a "living income" metric is met at household level, female workers may remain in de facto financial dependence. Ethnicity, caste, and disability status intersect with gender as compound vulnerability factors in several high-risk geographies (Dalit workers in South Asia; ethnic minority agricultural workers in Southeast Asia).
ILO Links
Indicators 1, 4, 5, 6
Driver 5
Weak Rule of Law & Labour Governance
Countries with low labour inspection density, high judicial corruption, restricted civil society space, or weak freedom of association protections consistently show higher forced labour prevalence independent of sector or commodity. This is not simply because forced labour goes undetected — it is because impunity removes the deterrent. The Walk Free Foundation Vulnerability Model scores countries on five dimensions: government response, civil and political rights, refugee flows, access to social protection, and conflict/instability. These dimensions correlate strongly with forced labour prevalence in the ILO's cross-country data. For due diligence purposes, weak rule of law in a sourcing country means that normal monitoring processes — audits, grievance mechanisms, corrective action plans — are less likely to produce accurate information and less likely to result in sustainable change even when they do.
ILO Links
Indicators 1–11 (all)
Driver 6
Buyer Business Model & Price Pressure
This driver is distinctive because it originates with the buyer company, not the sourcing context. Crane, LeBaron, and Soundararajan's 2019 analysis argues that modern slavery in supply chains is not primarily a governance failure in producing countries — it is a structural outcome of buyer purchasing practices that transfer cost and risk downstream until workers absorb them through unpaid or coerced labour. Practices identified include: prices set below the cost of legal, safe production; unrealistic lead times that require excessive overtime or outsourcing to unmonitored subcontractors; volume fluctuation that prevents suppliers from maintaining stable workforces; and payment terms that create supplier cash flow crises requiring short-term debt. The OECD Guidelines and CSDDD Recital 47 both explicitly identify harmful purchasing practices as a due diligence concern. This is why Module A asks whether due diligence findings are integrated into procurement decisions — because the buyer's own commercial behaviour may be a structural driver of the forced labour it is required to prevent.
ILO Links
Indicators 8, 9, 11
Implication for Due Diligence
A risk assessment that only checks commodity-country combinations against a published risk list addresses the macro-level expression of these structural drivers — not the drivers themselves. The OECD Step 2 requirement to assess severity and likelihood of actual and potential adverse impacts requires engaging with structural risk factors in the specific context of each supply chain segment. Module B question B.5 asks whether your risk assessment has done this. Where structural drivers are present and unassessed, an otherwise complete set of audit documentation will not satisfy a competent authority's preliminary assessment inquiry — because the authority will ask whether the risk assessment was adequate, not just whether audits were conducted.
Honest Limitations — What This Tool Cannot Do
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It cannot certify that your supply chain is free of forced labour
No tool, audit, or certification can make this claim. Forced labour is by definition hidden. What it can do is evidence that you took the required steps to identify and prevent it.
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It cannot assess the quality of your due diligence processes — only their existence
Whether your audits actually use worker interviews, whether your grievance mechanism actually works, whether corrective actions are actually followed through — these require human judgment. The tool asks whether you have these things; it cannot verify that what you have is effective.
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It cannot predict a specific competent authority's assessment
Different member states will develop different enforcement cultures and evidentiary standards, as they have under GDPR. A gap analysis that says "critical" means you have real exposure — it does not mean investigation is certain. An "elements present" rating does not mean investigation is impossible. Legal counsel who knows the specific authority is essential.
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It cannot assess your specific suppliers — only your processes for managing them
This tool assesses what you do as the economic operator. It does not access supplier data, third-party audit databases, or any external systems. Supplier-level data — audit reports, corrective action records, worker interview findings — should be logged in the Stage 4 Evidence Log manually.
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Commission guidelines (due June 2026) may require updates to questions and standards
This tool is built on the best available current interpretation. The implementation guidelines will be the definitive source on what "adequate" due diligence means under the regulation. The tool will update when they publish — reassess at that point.
Stage 1
Company Profiling & Risk Scoping
Establish the regulatory framework applicable to your organisation and generate an automated preliminary risk map based on your commodity and country exposure. Complete all fields accurately — this profile drives which assessment modules are activated.
Organisation Details Required
Primary member states where products are placed on the market or produced
Supply Chain Exposure Risk Scoping
Select all commodity groups present in your supply chain, including components and raw materials — not only finished goods.
Cotton & Textile Fibres
Includes cotton, viscose, synthetic fibres. High risk: Xinjiang (XUAR), Turkmenistan, Uzbekistan
Electronics Components & Semiconductors
PCBs, chips, displays, wiring harnesses. High risk: Malaysia (migrant workers), China (various regions)
Cobalt & Battery Minerals
Cobalt, lithium, graphite. High risk: DRC (artisanal mining), child labour documented
Cocoa & Coffee
High risk: Côte d'Ivoire, Ghana, Brazil. Child labour and debt bondage documented
Seafood & Fish Products
High risk: Thailand, Indonesia, Myanmar. Vessel-based forced labour, deceptive recruitment
State-imposed forced labour risk: Xinjiang polysilicon supply chain well-documented
Timber & Wood Products
High risk: Brazil, Malaysia, Indonesia, Myanmar. Overlaps with EUDR obligations
Other Agricultural Commodities
Palm oil, rubber, sugar, tobacco, tea. Specify in notes below
List your top sourcing origins by volume. Include countries where components or raw materials originate, not only direct supplier countries.
Preliminary Risk Map Automated Output
Risk data: ILO Global Estimates 2024 · US DOL ILAB 2024 · UFLPA Entity List (continuous) · Walk Free Index 2023 · Last tool update: March 2026. Verify currency before relying on output for regulatory purposes — see Specifications page.
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Indicative Assessment Only
This map is generated from your inputs against publicly available risk data (ILO, US DOL, known state-imposed forced labour geographies). It indicates where deeper assessment is required — it is not a determination of actual forced labour in your supply chain.
Regulatory Applicability Automated
Stage 3
Gap Analysis & Remediation Roadmap
Your assessment results ranked by regulatory significance. Gaps are classified against the EUFLR compliance floor and the ILO/OECD/Shift good practice ceiling. Prioritise critical gaps before the December 2027 application date.
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Critical Gaps
Investigation exposure
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High Priority
Due diligence weakness
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Medium Priority
Good practice gaps
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Elements Present
Documented
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Complete the Assessment Modules First
Gap analysis generates automatically as you complete the Stage 2 modules. Return here after completing at least Modules A, B, and C to see your preliminary gap report.
EUFLR Portal Readiness Checklist Launches June 2026
The Forced Labour Single Portal launches June 2026. Prepare now to monitor it systematically from day one. Tick off each preparatory action as completed.
Stage 4
Evidence Log & Investigation Preparedness
A timestamped record of your due diligence activities, structured for competent authority preliminary assessments. Document what you did, when, by whom, and with what outcome. Evidence predating a complaint carries significantly more weight than evidence compiled in response to one.
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Investigation Response Window: 30 Working Days
Under Article 17 EUFLR, competent authorities conducting a preliminary assessment may request information from economic operators. This evidence log is structured to enable a rapid, comprehensive response within that window. Maintain it continuously — not only when a complaint is received.
Investigation Scenario Simulation
Based on your Stage 1 risk profile, here is what a competent authority investigation scenario would look like for your highest-risk supply chain segment.
Complete Stage 1 to generate your investigation scenario
Once you have profiled your company and supply chain, this section will simulate a realistic preliminary assessment scenario and identify what evidence you could and could not currently produce.
Due Diligence Evidence Entries Add New Entry
Log each due diligence activity with full documentation metadata. Include negative findings and partial findings — not only clean results.
Complaint Response Mode
30-Day Preliminary Assessment Response Planner
A complaint has been received — or you anticipate one. Triage your current evidence position, plan your 30-working-day response, and identify what can still be strengthened before the window closes.
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Engage Legal Counsel Immediately
A competent authority preliminary assessment is a legal proceeding. This tool supports preparation — it does not replace legal advice. Engage EU trade and human rights counsel as your first action.
Complaint Details Triage Input
Response Window Art. 17 EUFLR
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Calendar Days Left
0
Working Days Left
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Submission Deadline
30 working days from receipt. Bar shows proportion of window elapsed.
Export & Download
Export, Save & Download
Your assessment data belongs to you. Download the tool to run offline, save your session to a file, and generate structured reports for board briefings, investor due diligence, or competent authority submissions.
Download Tool — Run Offline Recommended
This tool is a single self-contained HTML file. Download it to run entirely offline in any browser — no internet connection, no server, no third-party access to your data. Assessment data entered in a downloaded copy is stored only on your device. When running locally, all session data also persists between browser sessions automatically.
✓ Your data stays with you
No data is transmitted to any server. The tool runs entirely in your browser.
✓ Works fully offline
All assessment logic, risk data, and guidance is embedded in the file.
⟳ Update when guidelines publish
Download the updated v1.0 when Commission guidelines publish in June 2026.
euflr-readiness-tool-v0.9.html · Development International · March 2026
Save & Restore Session
Save your current assessment session — all Stage 1 company profile data, Stage 2 answers, notes, and evidence log entries — to a JSON file on your device. Restore it in any future session, in this browser or in a downloaded copy of the tool.
Save Current Session
Exports all your current answers, company profile, commodity selections, evidence log, and notes to a .json file. Save it somewhere secure — this file contains your compliance gap data.
Restore Saved Session
Load a previously saved session file to resume your assessment exactly where you left off. All answers, notes, and evidence log entries will be restored.
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Data security note
Session files contain your organisation's compliance gap assessment. Treat them with the same confidentiality as the report outputs — store securely and distribute only to authorised personnel. Development International does not receive or have access to any session data.
Report Configuration
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Auto-Disclaimer
All exports include: "This report reflects the company's self-assessment against Regulation (EU) 2024/3015 and supporting frameworks. It does not constitute legal advice and has not been independently verified."
