The European Union’s Corporate Sustainability Due Diligence Directive (CSDDD) is reshaping how companies approach human rights and environmental risks in their supply chains. In response, a new wave of digital “supply chain accountability” tools has emerged that map and trace suppliers across tiers, collect worker feedback, and visualize risks linked to a range of ESG indicators in real time. These tools have also renewed attention on the role of trade unions and civil society organizations (CSOs), whose on-the-ground knowledge into factory conditions remain indispensable for understanding supply chain risks and for making any due-diligence system meaningful.
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These tools promise something long overdue: a shared digital infrastructure that could make corporate accountability more visible, verifiable and scalable. But is that what’s happening in practice? Open Supply Hub’s new report, “Beyond Transparency,” based on interviews with 65 trade unions and civil society organizations around the world reveals a far more complicated reality. For many worker organizations, these technologies do not yet feel like the step-change they were promised. Rather than ushering in a new era of collaboration, they say these tools often resemble earlier compliance systems, just rebuilt on more sophisticated software and faster data pipelines.
As a union leader from Sri Lanka explained: “A digital tool is no different from an audit form if we’re only asked to feed in information. The whole promise of the CSDDD was meaningful stakeholder engagement but if the tool is used as a substitute for real engagement between companies and workers, then nothing has changed.”
A transformative opportunity
At their best, these digital tools could fundamentally reshape how global supply chain governance works. They offer the ability to map complex supplier networks across continents, reveal previously hidden tiers of production, and make due diligence more continuous, data-driven, and responsive to the realities workers experience on the ground.
In theory, digital tools could even democratize access to supply chain information if they are designed as open, transparent and participatory systems that allow workers, trade unions, and civil society groups to monitor, verify, and act on the very data that defines their working lives. For suppliers, they hold the potential to reduce duplication by consolidating multiple reporting systems. For brands, they present the possibility of shifting from reactive compliance towards proactive risk prevention and meaningful investments in safe and sustainable production.
This is why many organizations initially embraced these technologies: the hope that digitalization could finally shift from empty compliance exercises to truly meaningful engagement among various stakeholders in the industry.
But in practice, trade unions say that too many tools are replicating the same top-down, compliance-driven dynamics that have made systems to-date so ineffective. “Because many of these tools are designed first and foremost to meet brand reporting obligations under new due-diligence laws, efficiency and scale become the priority. The consequence is that the hyperlocal nuance and detail that make due diligence meaningful in addressing supply-chain issues are often stripped away,” said Shikha Silliman Bhattacharjee, a lawyer and researcher who has worked with grassroots unions for more than two decades.
How good intentions go wrong
The problem is not usually ill intent from companies or technology providers. Rather, under pressure to demonstrate readiness for the CSDDD and other due-diligence frameworks and at a time when many sustainability budgets are shrinking, companies are increasingly adopting digital tools as fast, standardized solutions. Interviews with trade unions and CSOs revealed three interconnected challenges with regard to digital tools for supply chain accountability.
Firstly, accessibility barriers exclude many of the very workers these systems are meant to support. Most digital tools assume stable internet connectivity, English literacy, privacy, and digital confidence, conditions that do not often reflect the realities of low-wage women workers in the garment sector. Even smaller women-led unions and grassroots NGOs often lack the devices, connectivity, or resources needed to participate in these systems themselves. A Sri Lankan women’s union told us, “The company asked us to use an app to report harassment, but most of our members share phones with male family members. How can we safely report in an app then?” Digital inequality means that those most affected by labor abuses frequently become the least visible within the very systems designed to identify and prevent those abuses.
Secondly, trade unions and CSOs stressed that many digital systems, even when well-intentioned, are being used as substitutes for the labor-management dialogues required under the CSDDD and similar frameworks. Worker “feedback” features and chatbot-based grievance tools are often presented as evidence of broad consultation, even when they lack escalation paths, follow-up mechanisms, data transparency, or any meaningful link to remedy. One Indian women’s union leader explained that some companies now openly say they do not need to engage with trade unions because they have a digital grievance tool, noting, “If companies use a digital tool instead of talking to us, they are not solving the problem, they are avoiding it.” Without genuine engagement, these systems create an illusion of participation; workers feed information into platforms but in reality they have no influence over how their concerns are interpreted or what actions follow. The result mirrors longstanding systemic failures, where information flows upward, while accountability remains distant.
Finally, workers and union representatives raised serious concerns about data governance and the ways digital platforms use and source worker information. As one Indonesian trade union leader said, “These platforms ask for sensitive information about working conditions, but workers don’t know who sees their data, how it is stored, whether it is shared or monetized and nothing changes for them.” An Indian union leader added that many platforms claim to brands that they hold large quantities of “worker data,” yet offer no clarity on where that data comes from, whether it is drawn from audits, scraped from third-party sources, or provided by unions themselves. This opacity, they said, fuels deep distrust among various stakeholders and weakens the credibility of the entire system.
In repressive settings, the risks escalate further. Union representatives from Myanmar, organizing under a military coup noted that even the smallest data leak about workers or union activity can carry serious personal danger. As one explained, “Here, a digital data point about a worker or their conditions is never neutral. Without real anonymity, an app can expose people to the authorities, and we have no idea what can happen to them.”
Charting a different path
So where do we go next? Digital tools are not going away, in fact, they are rapidly becoming the default architecture of global due diligence, especially with the rise of AI. The question is not whether these tools should exist, but how they should be built, governed, and used. If we want digital systems to strengthen, rather than sidestep, the kind of meaningful engagement the CSDDD envisions, then they must be redesigned with workers, unions, and grassroots organizations at the center, not at the margins.
Many of today’s tools were developed before these challenges were fully understood but now that the risks and gaps are visible, there is a responsibility for companies, policymakers, funders, and tech providers to address them. That means treating safety, accessibility, co-governance, reciprocity, and representation not as optional features but as non-negotiable requirements.
This is not easy work, and it will not happen overnight. But it is both possible and urgent and will demand collaboration across the entire ecosystem, from brands and auditors to unions and digital innovators.
Because in the end, if the workers who are most at risk and for whom due diligence legislation exists do not experience safety, voice, and remedy through these technologies, then all we will have built is a more efficient version of the status quo. That is the real test for digital tools: whether they shift power toward workers, not merely extracting data from them.
Nandita Shivakumar is a Stakeholder Engagement Manager at Open Supply Hub. Hannah Lennett is the Director of Stakeholder Engagement at Open Supply Hub. https://opensupplyhub.org/
