Development finance institutions play a determinative role in driving corporate investment and setting the terms of that investment and its corresponding impacts on human rights. For this reason, how governments regulate development finance is a critical issue for the Business and Human Rights agenda. This discussion memo provides preliminary guidance on how to use National Action Plans (NAPs) around Business and Human Rights to promote human rights due diligence in the context of development finance. It describes the connection between the UN Guiding Principles (UNGPs) and development finance and identifies potential policy recommendations. We welcome your reactions and inputs to expand and refine the policy recommendations and examples herein.