In brief:

• Our new US corporate human rights index examines the human rights policies and commitments of 54 US companies in the technology, apparel, extractives, automotive and agrifood sectors. The purpose: to identify any major changes made in 2025. We also analyze developments over the past year related to business and human rights in the US.
• Our finding: Companies’ core human rights policies and commitments remain largely unchanged, in contrast to some shifts in human rights-related AI and content moderation policies, and well-documented rollbacks on commitments related to DEI and climate. See all findings here.
• While commitments haven’t changed on paper, our analysis of companies’ responses to changing policies, regulations and rhetoric in the US paints a more alarming picture, which we explore in the four trends outlined below.
• US tech companies’ increasing and unregulated power poses a particular threat. Smart incentives and mandatory human rights due diligence are the obvious starting points to reverse this trend, coupled with liability for tech companies that don’t comply.
• Responsible business across sectors is still possible, and there have been some modest examples of companies and industry associations defending the business and human rights agenda. We need more companies not only to stay the course on policy, but to meet the moment by defending the institutions and initiatives that support responsible business and by strengthening the implementation of their existing commitments.

Over the past two decades, there has been significant progress made by many major US and other global companies to advance corporate respect for human rights. They have adopted human rights policies, implemented human rights due diligence, and remediated harms. The US and other governments have also taken important steps, such as working to eliminate forced labor and adopting human rights due diligence legislation.

But with the rise of authoritarianism, narrow economic nationalisms and corporate capture around the world, we risk losing these gains. In turn, local communities and workers face even more severe risk. While the gaps between policy and practice have long been apparent in the business and human rights arena, those gaps may widen at a time of persistent human rights abuse and new complex risks related to issues such as critical minerals and AI.

A shifting context in the US

Business and investors are adapting to a fast-shifting landscape regarding geopolitics, regulation, and supply chain reorganization and costs.

The restructure of the State Department’s Bureau of Democracy, Human Rights, and Labor (DRL) and the dismantling of a majority of the US Agency for International Development (USAID) programs eradicated technical, financial and diplomatic support to US companies navigating global human rights risks. The business and human rights team at DRL was eliminated, including those working to support the Voluntary Principles on Security and Human Rights; internet, technology and human rights; human rights due diligence; and business advisories on human rights risks in particular regions and sectors. The narrowing of human rights issues covered in the Department’s annual country reports curtails companies’ access to comprehensive, vetted information on risks in countries from which they source or operate in. Among cancelled USAID projects were funding for the Extractives Industries Transparency Initiative to address corruption and supporting US companies to advance women’s equality in their agricultural commodity sourcing. Other lost programs advanced rule of law and civic space. In addition, programs led by the Department of Labor’s Bureau of International Labor Affairs supported company efforts to eliminate child and forced labor. The rollback of these programs leaves US companies more exposed to human rights risks and less equipped to operate responsibly in complex global environments.

On domestic supply chains and operations, in July, the Washington Post reported that the Department of Labor would be cutting 60+ labor rights regulations, including care work minimum wage protections and union organizing rights for migrant farmworkers. The Executive Order on Unleashing American Energy advances extractive industries development in the US, noting that “in recent years, burdensome and ideologically motivated regulations have impeded the development of these resources.” Such deregulation could heighten companies’ domestic human rights risks and harm to communities – including Tribal Nations – and workers.

Both the US House of Representatives and Senate are currently considering a bill that would include federal penalties for protest action at pipeline sites, further criminalizing environmental defenders advocating for the safety of their communities and to address the climate crisis. These bills build on legislation already enacted in 23 states limiting protests at pipelines or critical infrastructure sites. Such civic space restrictions create an “information black box,” leaving companies and investors with gaps in knowledge about negative human rights impacts. Civic space restrictions also threaten democracy, which, along with full enjoyment of civic freedoms, has been linked to an increase in GDP per capita.

With regard to technology, the US government appears to be pursuing a growth-at-all-costs approach to AI. The recent AI Action Plan proposes to scale back regulation, tie state funding decisions to those with minimal restrictions, require vendor AI systems to be free of “ideological bias,” and fast-track environmental permits for AI infrastructure.

Within this changing context, there’s a risk of companies using weakened government programs, laws, and regulations as a reason to roll back their longstanding human rights commitments and initiatives. There’s also a risk that growing polarization and the increasingly charged tone of political discourse discourages companies from expanding – and even publicly discussing – their longstanding human rights policies and practices.

Our findings

There have already been well documented rollbacks by companies on DEI and some climate commitments, in addition to – in the technology sector – responsible AI and content moderation.

The Business & Human Rights Resource Centre assessed whether company rollbacks have also occurred across a broader range of core human rights policies and commitments. We reviewed the policies and commitments of 54 of the largest US companies in five high-risk sectors. Our finding: not yet. Beyond the exceptions noted above, companies have largely maintained their human rights policies and commitments thus far.

However, a closer examination of actions by US companies amidst shifts in policies, regulations, and rhetoric in the US and across the globe reveals a more complex and concerning picture.

What follows are four trends apparent today regarding US company action on human rights, along with reasonable, responsible steps that leading companies could and should be taking instead. Together, these trends underscore the need for mandatory human rights and environmental due diligence regulation and strategic incentives to steer businesses toward greater respect for human rights – and their own long-term sustainability and competitiveness. These trends also underscore the importance of companies not just staying the course, but of rising to the moment by defending the institutions that support responsible business and strengthening the implementation of their existing human rights commitments.

Trend #1: Emboldened, some companies are lobbying against human rights-related regulations; others are defending them

Despite positive progress to strengthen corporate respect for human rights over the past two decades, company voluntary action has proven insufficient to prevent harm; there’s an urgent need for regulation in various jurisdictions, including the EU and the US, given the power of companies domiciled in these locations. The interplay between the EU and the US on regulation is especially acute amidst domestic political developments in the US. For instance, in October, a group of 16 State Attorneys General sent letters to several companies urging them to not comply with the landmark Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD) – corporate due diligence and transparency legislation in the EU.

They highlighted that the rules are conducive to competitiveness, growth, and long-term value creation and subsequent returns for investors. Some US-headquartered companies and networks, such as Mars and the tech-focused Global Network Initiative, have also continued to publicly support the CSDDD in 2025.

Meanwhile, tech companies have been lobbying against regulation in both Europe and the US. The Computer & Communications Industry Association (CCIA) – which includes many US-headquartered companies – urged a pause on implementation of the EU AI Act and its General-Purpose AI Code of Practice (GPAI). The Act is considered by some as the world’s first comprehensive AI law. In the first half of 2025 in the US, federal lobby spending by major tech companies against state AI regulation surged, with Meta spending a record USD 13.8 million. The sector’s overall sentiment on regulation seems to have changed since 2023, when major tech firms made voluntary commitments to “advance a generative AI legal and policy regime,” pledging to follow them until formal regulations arrived. Also in 2023, some tech executives were publicly supportive of regulation: CEO of OpenAI Sam Altman testified before Congress that regulation was “essential,” Kent Walker, President of Global Affairs at Google & Alphabet, argued “AI is too important not to regulate,” and Apple CEO Tim Cook supported some “rules of the road.”

Encouragingly, even beyond the examples on the EU CSDDD above, there have been several major US industry associations and multi-stakeholder initiatives which have recently and publicly supported strong government support for labor and human rights. The American Apparel & Footwear Association (AAFA) and the Fair Labor Association (FLA) – which collectively represent hundreds of US companies – highlighted the value of the Department of Labor’s Bureau of International Labor Affairs’ (ILAB’s) partnership to the industry and urged for the protection of ILAB. AAFA also expressed “alarm” over the imminent dismantlement of USAID in early 2025.

What the moment demands: Companies to defend strong government-led action on business and human rights and core provisions of the EU CSDDD, and ensure that their industry associations’ lobbying is consistent with their established human rights commitments.

Trend #2: Companies’ responses to genocide and conflicts around the world are testing the credibility of their human rights commitments

In a 2025 report, B4Ukraine found that American firms paid USD 1.2 billion in profit taxes to the Kremlin in 2024 –on par with 2023 levels, but well above the USD 915.7 million recorded in 2021. US authorities investigated four large US semiconductor producers in September 2024, – Analog Devices, Advanced Micro Devices (AMD), Intel and Texas Instruments – whose products allegedly constitute over 40% of the components in Russian weapons found on the Ukrainian battlefield. Other conflict and high-risk contexts where business operations are linked to systemic violence and human rights abuses include eastern Democratic Republic of Congo and Myanmar.

What the moment demands: Companies to adhere to international standards, which demand heightened human rights due diligence in conflict areas regarding their operations and supply chains, proportionate to the scale and severity of the risks to people. Where this sharper focus is not possible or where a business model that would avoid contribution to "foreseeable harmful effects" on civilians is unfeasible, then responsible exit from the conflict must be considered.

Trend #3: Companies are shifting supply chains in response to tariffs, which creates new human rights risks, particularly when moves are made quickly in or towards high-risk sourcing environments

The Resource Centre is tracking the impact of US tariffs on apparel and footwear supply chains. New US tariffs on apparel imports are set to significantly impact key producing countries like China, Bangladesh, Sri Lanka, Cambodia and India, with global buyers expected to shift orders to lower-cost countries to avoid increased expenses. Nike, for instance, has indicated that it will reduce manufacturing in China to soften the impact of tariffs. David’s Bridal reportedly moved production out of China. Walmart put garment orders from Bangladesh on hold.

Manufacturers in countries now subjected to higher tariffs anticipate order cancellations, reduced or paused orders, and mounting pressure to absorb costs or provide discounts from major retailers. Related human rights risks include unpaid work, poor working conditions, and suppression of unions and freedom of association, with particular impact on women workers. The negative impacts have already begun. Tiruppur, India – Tamil Nadu’s garment hub – is reportedly experiencing an economic and humanitarian crisis, with a 50% US tariff on textiles leading to sharp export declines and widespread job losses. In Lesotho, 5,000 textile workers were allegedly put on three-month unpaid leave as the industry struggles with the impact of US tariffs and reduced orders.

Companies in other sectors are also shifting – or considering shifting – their supply chains to avoid heightened costs related to tariffs. As one example, HP reportedly accelerated plans to move manufacturing of many North America-bound products out of China.

What the moment demands: If companies choose to change suppliers due to higher costs imposed by US tariffs, they must ensure they exit supplier relationships responsibly, and that any new suppliers have the policies and practices in place that ensure respect for human rights. This imperative requires enhanced human rights due diligence on both exit and entry into new production hubs.

Trend #4: US tech companies’ increasing and unregulated power threatens human rights everywhere

The power of the global technology sector is overwhelmingly concentrated in the United States. US-headquartered tech companies – Alphabet, Amazon, Apple, Meta, Microsoft, and NVIDIA, among others – drive the performance of major global stock indices and exert significant influence over markets, policy and public discourse. They have been allowed to attain unparalleled scale and global reach; their products and platforms are used by billions, and their technologies and products are rapidly evolving. The scope of their associated human rights impacts is correspondingly vast. Salient issues include privacy and freedom of expression as well as supply chain risks related to land and water, Indigenous Peoples and labor rights.

In addition to the industry’s lobbying efforts (Trend #1) and tech companies’ roles in conflicts around the world (Trend #2), we’ve seen two other key areas of human rights-related developments in the sector.

First is the accelerating convergence between the tech and defense industries, which exponentially multiplies the human rights risks already embedded in both. Major tech companies are deepening their ties with militaries around the world, with some developing drones, anti-drone technologies, and other tools and AI-backed weapons systems. As one indication of the increasing closeness of the industry to armed forces, in June, four current and former executives from Meta, OpenAI and Palantir were pronounced lieutenant colonels in a newly established US Army unit, Detachment 201.

The expansion of tech companies’ roles in defense introduces new human rights concerns – they are selling new, largely unregulated technologies for armed services to use in new ways. There are also questions about which governments companies sell their technologies to – and who decides. Associated human rights concerns relate to enhanced impacts on civilian harm, privacy and freedom of expression, among others. The extent of these impacts remains unknown: OpenAI only reportedly removed language banning the use of its technology for weapons development and military purposes in 2024. Meta was reported to have taken a similar step, also in 2024. Google removed its commitment not to design or deploy AI for weapons earlier this year. But per Trend #2, the Resource Centre and others have already been tracking allegations of how these technologies have contributed to mass civilian harm in Gaza.

As this trend continues to unfold, one key principle must be front and centre: any company supplying technologies for military purposes has a responsibility to ensure that its products are not used for repression of legitimate voice and protest, nor to facilitate military actions that violate international human rights or humanitarian law. Companies need to know where and to whom their technologies are sold and licensed.

Second is discrimination and bias in tech sector products. A recent study by the Business & Human Rights Resource Centre and World Benchmarking Alliance found that 11 leading tech companies fall short in addressing systemic harms related to gender and race. Examples of harm include negative health impacts on workers, many of whom are women; bias and mistakes in facial recognition and ID verification tools leading to erroneous arrests; and platforms facilitating the proliferation of misogynistic hate speech and fueling violence. These have long been risks resulting from the industry. In today’s context – with firms scaling back their DEI programs, companies like X, Meta and YouTube changing their approaches to content moderation, and with surveillance and facial recognition technology being used by governments in mass immigration raids, detention and deportation – they are of heightened concern.

What the moment demands: The tech sector is advancing rapidly and could contribute to improving lives. However, current deregulated approaches are generating substantial human rights risks as well as undue influence over the rules that govern it. The sector must be regulated and held accountable. Mandatory human rights due diligence is the obvious starting point, locating the burden of human rights risk identification and mitigation with those responsible companies before release of new systems and during their roll-out.  Liability for failure to meet the requirements is a critical tool of accountability. Equally, incentives in the form of public subsidies should be contingent on companies meeting internal business standards for human rights and environmental protection.