Why “we didn’t know” is no longer enough: how to truly move the dial on HRDD

16th Apr 2026

Assessment, Human Rights Due Diligence, Insights, Worker Rights

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Many organisations today can point to human rights audits, policies and training across their supply chains. Often, they have invested heavily in all three.

Yet serious human rights risks still surface late, or only after harm has already occurred. Forced labour, harassment, coercion and abuse can remain hidden even in supply chains that appear strong on paper.

The issue is rarely a lack of intent. More often, it is a reliance on tools that were never designed to do what human rights due diligence (HRDD) now requires.

Audits are an important tool, but they are not a due diligence system. In this article, we explain how to take your HRDD to the next level, and why in 2026, “we didn’t know” is no longer a defensible position.

The limits of assurance

Audits play a valuable role in establishing baseline compliance and identifying clear non‑conformances. But they have limits. They assess compliance at a moment in time, rarely surface severe harm or systemic drivers of risk, and do not show whether risks are reducing in practice.

As expectations from regulators, investors and stakeholders continue to rise, this distinction matters. Organisations are increasingly judged not on whether they have systems in place, but on whether those systems are effective.

A different way to think about assessments

At Impactt, we see assessments not as a compliance exercise, but as a decision‑making tool.

Effective HRDD requires organisations to identify salient risks based on severity to people, understand actual impacts (not just policy gaps), prioritise action based on risk exposure, and demonstrate whether those actions are working over time.

This means moving beyond generic assurance towards risk‑led, worker‑centred insight, grounded in real working conditions and lived experience.

What Impactt’s assessments actually involve

Across all our assessment work, from rapid diagnostics to full Human Rights Impact Assessments, we apply the same core approach:

  • Severity‑based risk prioritisation, grounded in international standards
  • Direct worker engagement, to surface realities that desk‑based reviews and audits miss
  • Rootcause analysis, not just symptoms or non‑conformances
  • System‑focused insight, linking findings directly to governance, decision‑making and action

The difference is not the methodology, but how deep and how fast we go, depending on risk, exposure and the decisions that need to be made.

In practice, this approach consistently surfaces materially different findings.

Independent comparative research has shown that Impactt’s assessments identify over twice as many issues on average (2.3×) as traditional audit‑led approaches at the same sites and up to three times more issues in higher‑severity areas, including forced labour indicators, coercion, harassment and discriminatory or abusive treatment.

These are precisely the risks that are least likely to be detected through documentation reviews or short, compliance‑led site visits — and most critical for effective HRDD.

Rapid diagnostics: clarity when speed matters

In many situations, organisations do not need, or are not ready for, a full Human Rights Impact Assessment (HRIA). What they need first is clarity.

Impactt’s rapid diagnostics apply the same methodology as our deeper assessments but are designed to move faster and focus on what matters most. They combine targeted worker engagement with a focused review of systems and practices to understand where risk really sits, why, and what to do next.

They are typically used where risk exposure is unclear or uneven; audits have stalled decision‑making; regulatory, investor or reputational pressure is increasing; or leadership teams need credible evidence to act.

Rapid diagnostics are not a shortcut, and they do not replace a full HRIA where risk is severe. Instead, they provide decision‑ready insight — enough clarity to prioritise action with confidence.

Every engagement is bespoke. You bring what you know and what you need — we help bridge the gap.

From assurance to evidence

HRRD is no longer judged on activity alone. Organisations are increasingly expected to show that risks are being identified, prioritised appropriately, and reduced over time.

If audits are no longer giving you the answers you need, we can help.

Talk to us about where risk is uncertain, where decisions feel stuck, or where clearer evidence is needed to move forward — and we’ll help you work out where to start.

Get in touch with Robin Bishop, at robin@impacttlimited.com, to discuss your needs.

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