Inside the Commission's June 2026 guidelines
On 30 June 2026, the European Commission published its Guidelines on the Forced Labour Regulation, alongside a new online information portal intended to help companies prepare for full application in December 2027. This was the first substantial piece of interpretive detail issued since the Regulation entered into force in late 2024, and it's worth understanding what it actually adds – and what it still leaves open.
The guidelines do three main things. First, they point companies towards the OECD's six-step due diligence framework as the reference structure for assessing and addressing forced labour risk, without making that framework legally binding. Second, they set out a penalty-calculation methodology built around the gravity and duration of the violation plus aggravating and mitigating factors, while explicitly leaving the specific numeric formula to individual member states to finalise. Third, they published a provisional list of national competent authorities – the bodies that will handle FLR investigations within each member state – while flagging that this list remains subject to change as member states complete their own institutional arrangements.
What the guidelines don't yet resolve is arguably more significant for compliance planning. The forced labour risk database – intended to give companies and authorities a shared reference point on high-risk geographies, sectors and products – remains under development, with no confirmed launch date. Until it exists, both companies conducting risk assessments and authorities deciding where to focus investigations are working from a patchier picture than the Regulation ultimately intends.
The guidelines also don't specify exactly what evidentiary threshold constitutes a 'substantiated concern' sufficient to trigger a formal investigation – a term used throughout the Regulation but left undefined in operational terms. Companies are left to infer, from the OECD-framework reference and general enforcement principles, roughly what a credible risk assessment needs to demonstrate, without a checklist to work against.
There's an external pressure dimension worth noting too. The United States has an active Section 301 investigation examining whether trading partners – including EU member states, among some sixty economies under review – are adequately blocking forced-labour-linked imports, with the potential for tariffs of up to 12.5% attached to that assessment. That creates a degree of urgency on the EU side to demonstrate its own enforcement architecture is credible, which may accelerate how quickly remaining gaps like the risk database get filled in.
For compliance teams, the practical takeaway from the June 2026 guidelines is that the direction of travel is now clear even where the details aren't finished: due diligence aligned to the OECD framework, documented and evidenced, is the de facto standard the Commission expects – regardless of whether the risk database or final penalty formulas exist yet.
Speeki tracks EU regulatory developments relevant to due diligence and supply chain governance as part of its ongoing standards work. Speeki is an accredited certification body; current accreditation details are available at speeki.com.