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2026-10-197 min read3

Korea's Proposed Human Rights and Environmental Due Diligence Act — Large Companies Face Annual Supply Chain Checks; Why Exempt SME Suppliers Will Still Get the Questionnaire First, and How to Prepare

A newly proposed Korean bill would require companies with 1,000+ employees or KRW 500 billion+ in revenue to run annual human rights and environmental checks on their supply chains. This guide explains how the bill is built and how SME suppliers, which are exempt but will be the first to get buyers' questionnaires, can prepare.

KITIM Consulting Team

The Bill at a Glance — What Was Proposed

On August 27, 2026, Rep. Park Ji-hye introduced the Human Rights and Environmental Due Diligence Act for Corporate Sustainability and Responsible Management. The goal is to help Korean companies respond to overseas rules such as the EU Corporate Sustainability Due Diligence Directive (CSDDD) and Germany's Supply Chain Due Diligence Act (LkSG).

  • Who it covers: Companies with 1,000 or more full-time employees, or annual revenue of KRW 500 billion or more. SMEs are not directly covered.
  • Core obligations: Every year, covered companies would draw up a due diligence plan and get it approved by the board. They would also check for violations at least once a year, prepare and regularly publish a due diligence report, and set up a way for affected people to seek remedy.
  • New bodies: A Human Rights and Environment Business Committee under the Minister of Finance and Economy, which would review cases and resolve disputes, and a Fund for Victims of Human Rights and Environmental Harm.
  • Keep in mind that this is only a bill. It has not passed. The coverage thresholds, effective date, and penalties could all change during committee review. The bill follows the National Human Rights Commission's August 20 call for due diligence legislation. It is also separate from the "ESG Framework Act" being discussed in the National Assembly ESG Forum.

    SMEs Are Exempt — So Why Prepare Now?

    The bill targets large companies' own supply chains. To find and check risks, those companies will have to send questionnaires to their tier-1 and tier-2 suppliers, run on-site audits, and rewrite contract terms. The law applies to the large company, but much of the actual work lands on the SMEs that supply it.

    Many large companies already check their suppliers to prepare for the EU CSDDD and the EU Forced Labour Regulation. A domestic law would likely widen that work from export supply chains to all domestic supply as well.

    Korea's current K-ESG supply chain due diligence guidelines are voluntary. Once due diligence moves from a recommendation to a board-approved, publicly reported duty, buyers will need evidence behind their own reports. That changes what they ask of suppliers: saying "we comply" won't be enough, and you will need records that show it.

    What Buyers Will Ask — Checkpoints by Area

    Human rights

  • Employment contracts, payroll records, and working-hour logs
  • Whether migrant workers pay recruitment fees, and whether the company holds their passports or ID cards
  • Policies prohibiting child labor and forced labor
  • Workplace safety management and accident history
  • Whether a grievance channel actually works in practice
  • Environment

  • Air, water, and waste permits, and any history of violations
  • Chemical inventory and how chemicals are managed
  • Greenhouse gas data, including estimates based on energy use
  • Lower tiers

  • How well you know your tier-2 suppliers and where your raw materials come from
  • Types of evidence

    Buyers usually look for three things: policy documents, operating records, and a record of fixes made. The most common problem is having a policy but no records. If your work rules describe a grievance procedure but the complaint log is empty, a buyer will likely assume the procedure isn't actually used.

    A Three-Step Roadmap for Supplier SMEs

  • Assess where you stand: Use a self-assessment checklist to list your human rights and environmental risks. Gather the ESG questionnaires buyers have already sent you and pull out the questions that keep coming up.
  • Build a minimum system: Put in place a human rights policy statement, a grievance procedure, records for managing migrant workers, and a log of environmental permits. Name a person responsible for each.
  • Package your evidence: Build a supply chain response file you can reuse for any buyer's questionnaire, and record every fix with its date.
  • Watch the contract terms. When clauses on due diligence cooperation, audit access, or termination for violations show up, check:

  • How wide and how frequent audits can be, and who pays for them
  • Whether the buyer can terminate without first giving you a chance to fix the problem
  • How much information you must share, and how your trade secrets are protected
  • Available Support and How KITIM Can Help

    Existing programs can help, such as the free K-ESG supply chain due diligence consulting and joint ESG support programs for large companies and SMEs. Timing and eligibility change each year, so check the current calls before applying.

    As the bill moves through review, watch for:

  • Whether the 1,000-employee / KRW 500 billion thresholds stay as they are
  • How long the grace period before enforcement will be
  • Whether the bill adds a duty for large companies to support their suppliers
  • KITIM helps supplier SMEs prepare for due diligence requests step by step, from a supply chain ESG self-assessment and building a human rights management system to preparing answers for buyers' ESG questionnaires. If you've received a buyer questionnaire or found new due diligence clauses in a contract, request a consultation with KITIM. We'll start by checking how much your current records already let you answer.

    Human Rights and Environmental Due DiligenceSupply Chain Due DiligenceSupplier ESGHuman Rights ManagementSME ESGCSDDD
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