Over the past few years, various countries in the Global North have passed new legislation imposing human rights reporting requirements on companies [...], as well as mandatory human rights due diligence...

The Dutch law introduces a duty of care [zorgplicht] to prevent the supply of goods or services which have been produced using child labour... [I]t concerns a generic duty to exercise due diligence [gepaste zorgvuldigheid], which the law elaborates...

Several aspects make the Dutch law distinct in the wider legislative trend. First, it dictates the appointment of a regulator [toezichthouder] (art. 3), who publishes the corporate human rights due diligence statements in an online public registry (4.5)...

Second, it is the first to introduce criminal sanctions for a failure to exercise human rights due diligence...

Third, the law attempts to incorporate an existing mechanism of responsible business conduct. Critics of the law worried that binding legislation would undermine the existing model in the Netherlands for addressing complex business and human rights issues through so-called ‘covenants’ (Agreements on Responsible Business Conduct)... Notably, the law indirectly includes the covenants in article 5.4...

Several details of the law remain to be specified through implementing decrees [algemene maatregelen van bestuur]... The scope of the law is currently limited to child labour, but it could prompt the development of broad human rights due diligence legislation in the future.