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EU Forced Labour Regulation readiness checklist

Twenty questions across six areas a company may be asked about when an authority looks at forced labour risk in a product's supply chain. Answer them here and get a readiness summary — calculated in your browser. Nothing is stored, sent or tracked.

Published by Libera Europe · Last reviewed 5 October 2026

1. Supply-chain mapping

1. Supply-chain mapping

You cannot assess a product's forced labour risk without knowing where and by whom it was made. Risk assessment method

  1. We know which of our products reach or leave the EU market, and their direct suppliers.

  2. We know the production sites (not only the legal entities) for higher-risk products.

  3. We know which labour agencies or recruiters supply workers to those sites.

  4. Gaps in our map beyond tier 1 are recorded, not ignored.

2. Documented risk factors

2. Documented risk factors

Risk-based prioritisation needs reasons someone else can follow. Scoring methodology

  1. Each supplier/site has a documented risk rating by country, sector and recruitment model.

  2. We screen suppliers against official lists (e.g. the UFLPA Entity List, sanctions lists) and record the date.

  3. We record why each supplier was prioritised the way it was.

  4. The assessment is repeated on a schedule or when circumstances change.

3. Worker access

3. Worker access

Many indicators are only visible to workers; silence without verified access is not reassurance. Why zero reports is not zero risk

  1. Workers at higher-risk sites have a confidential way to raise concerns in their language.

  2. Access to that channel has been checked at agreed points, with dated results.

  3. Workers can raise concerns without a supervisor or agent seeing the report.

4. Investigation process

4. Investigation process

A signal is only useful if a person reviews it and decides what happens next. Escalation protocol

  1. There is a written process for reviewing signals and opening investigations.

  2. Named people are responsible for review, with severe or safeguarding signals prioritised.

  3. Decisions are recorded with dates, reasons and owners.

5. Remediation and effectiveness

5. Remediation and effectiveness

Remediation claimed but not verified with workers should stay open. Remediation example: fee repayment

  1. Remediation actions have owners and due dates.

  2. We verify remediation with evidence beyond the supplier's own attestation.

  3. We check effectiveness later — e.g. through follow-up worker voice or re-verification.

6. Evidence trail

6. Evidence trail

Authorities may request information on how risk is identified and addressed during an investigation. EUFLR preparation guide

  1. Screening, signals, decisions and remediation are kept in one dated record.

  2. We could produce a summary for a specific product or supplier within days, not weeks.

  3. Changes to the record are logged, so its history can be followed.

Your readiness summary

0 of 20 questions answered. "Not sure" counts as a gap: if nobody can say, it probably is not documented.

  • 1. Supply-chain mappingNot yet answered
  • 2. Documented risk factorsNot yet answered
  • 3. Worker accessNot yet answered
  • 4. Investigation processNot yet answered
  • 5. Remediation and effectivenessNot yet answered
  • 6. Evidence trailNot yet answered

This summary is a self-assessment aid. It is not legal advice, not a compliance determination, and no result — including "documented" in every area — proves compliance with the EU Forced Labour Regulation or any other law.

Turning gaps into a plan

Start where risk is highest, not where answers are easiest. Mapping and risk factors come first, because they decide where worker access and investigation effort should go. The risk assessment guide includes a copyable template, and the EUFLR preparation guide sets out a timeline to December 2027. If you want to test the workflow on one supplier group, Libera runs 8–12 week pilots.

Sources and method

The six areas reflect the practical foundation of risk-based forced labour due diligence described in Regulation (EU) 2024/3015, European Commission material and ILO guidance. The checklist is a self-assessment aid only. It is not legal advice, not a compliance determination, and no result proves compliance with any law.

Libera produces risk indicators as prompts for human review, not findings. It does not determine that forced labour occurred, does not guarantee compliance with any law and is not legal advice.

Related intelligence

EU Forced Labour Regulation: 2027 preparation guide

What Regulation (EU) 2024/3015 does, the timeline, and a preparation path.

Forced labour risk assessment: method and template

A step-by-step method and a copyable assessment template for supplier prioritisation.

EUFLR vs CSDDD vs UFLPA vs modern slavery acts

Four different regimes compared: who they bind, what they require, how they bite.

Libera puts this workflow in one place: structural screening, confidential worker signals with verified access, human review, cases, evidence and remediation records.

Request a pilotSee the platform