FLUKE
Kimball Electronics
Tolomatic
Industrial Scientific
AHEAD
roboception
FLUKE
Kimball Electronics
Tolomatic
Industrial Scientific
AHEAD
roboception
By Acquis Compliance | Thu Aug 21 2025 | 2 min read

Table of Contents

On August 19, 2025, six of the world’s most influential automotive manufacturers – Ford, General Motors, Honda, Nissan, Stellantis, and Toyota – jointly issued a formal letter to their suppliers, launching what may become the most significant forced labor compliance shift the industry has seen to date. Through the Automotive Industry Action Group (AIAG), these OEMs are aligning behind a single, standardized approach: the Due Diligence Reporting Template (DDRT).

This isn’t a soft suggestion or a vague policy vision. It’s a definitive industry-wide expectation that, beginning September 2025, select suppliers must begin forced labor risk reporting through the DDRT. By mid-2026, this requirement will expand to cover the broader supplier network. The message is clear: prepare now or risk being left behind.

Why This Shift Matters

The automotive sector is under growing scrutiny as regulators around the globe take a harder stance on forced labor. The United States’ Uyghur Forced Labor Prevention Act (UFLPA), Germany’s Supply Chain Due Diligence Act (LkSG), the EU’s Corporate Sustainability Due Diligence Directive (CSDDD), and Canada’s Fighting Against Forced Labour Act all impose stricter requirements for transparency, traceability, and human rights enforcement.

Previously, OEMs took fragmented approaches to supplier compliance, issuing their own standards and conducting assessments independently. That fragmentation led to inefficiencies, duplicated audits, and inconsistent expectations across the supply chain. With the DDRT, the industry is converging on a unified standard, giving suppliers one template to satisfy multiple customer requirements.

What Is the DDRT?

The Due Diligence Reporting Template (DDRT) is a standardized disclosure document developed by AIAG to allow suppliers to report on forced labor risks and controls within their own operations and across their upstream supply chain. It's built to be flexible enough for companies at different stages of due diligence maturity, yet robust enough to meet the emerging global legal frameworks.

Suppliers filling out the DDRT can expect to disclose information across several key categories:

  • Company Scope & Policy: Describing the organization’s policy on forced labor and human rights, and who is responsible for overseeing it.
  • Risk Screening: Detailing what tools (e.g., Kharon, Altana, Resilinc) are used to identify high-risk suppliers or geographies.
  • Facility-Level Risk: Reporting on regions, facilities, or processes that present elevated forced labor risk.
  • Mitigation Measures: Describing how risks are addressed, whether through disengagement, capacity building, audits, or other actions.
  • Training Programs: Explaining what internal and supplier training efforts are in place.
  • Reporting Cadence: Stating how frequently due diligence is performed and updated.

This framework ensures that data can be rolled up consistently across OEMs and provides regulators with an auditable, comparable due diligence record.

DDRT vs. CMRT/EMRT: Not the Same Thing

A common misconception is that the DDRT replaces existing conflict minerals templates like the CMRT (Conflict Minerals Reporting Template) or EMRT (Extended Minerals Reporting Template). It doesn’t.

Those templates are focused on specific materials – such as tin, tungsten, tantalum, gold (3TG), cobalt, and mica. The DDRT, on the other hand, applies broadly to labor risks across the entire supply chain, regardless of the material. It focuses on worker treatment, not mineral sourcing.

Together, these tools form a comprehensive picture of both material and labor risks. But they are not interchangeable. Compliance teams will need to treat them as complementary processes.

What’s Driving This Acceleration?

This joint letter is more than a formality. It reflects a growing regulatory trend where governments are moving from voluntary principles to legally binding enforcement. Consider the following developments:

  • Under UFLPA, U.S. Customs and Border Protection detained over \$1 billion in goods in 2024 alone for forced labor risk.
  • The EU Forced Labour Regulation (EU 2024/3015) will empower EU authorities to ban products suspected of forced labor origins.
  • The German LkSG is already requiring Tier 1 suppliers to disclose their human rights policies and risks.
  • The EU CSDDD will extend those obligations deep into the supply chain, creating direct liability for non-compliance.

These laws are converging on a single theme: if you can’t trace your supply chain and prove it’s clean, your shipments and contracts are at risk.

The Compliance Timeline

  • September 2025: Targeted suppliers must begin submitting DDRTs to their OEM customers.
  • Mid-2026: Annual DDRT reporting becomes expected across a broader group of suppliers.

Suppliers should treat these dates as hard triggers. Waiting for an OEM-specific request is a mistake.

Real-World Risk: What’s at Stake?

Failure to comply could mean:

  • Shipments detained at borders
  • Disqualification from sourcing programs
  • Legal liability and fines under foreign law
  • Damage to brand reputation and customer trust

The DDRT isn’t a formality—it’s a signal that forced labor due diligence is becoming as fundamental as financial auditing or material testing.

What Should Suppliers Do Now?

  1. Download and review the DDRT to understand the required disclosures.
  2. Evaluate your current due diligence process and compare it against DDRT expectations.
  3. Screen your supply chain using risk intelligence platforms like Kharon or Altana.
  4. Implement a cadence of documentation, risk assessment, and mitigation, including escalation paths for red flags.
  5. Align with the AIAG Automotive Guiding Principles, which underpin the DDRT.

The Bigger Picture

This joint OEM commitment is not just about compliance; it's about industry alignment on ethics, transparency, and trust. It shows that the largest players in automotive manufacturing are moving together to eliminate blind spots in the supply chain.

At Acquis Compliance, we help suppliers automate, validate, and scale due diligence efforts using tools aligned with the DDRT. Whether you're just starting or maturing your human rights program, this is your wake-up call.

Because the road to compliance isn’t optional anymore — it’s operational.

text Need help integrating DDRT into your compliance program? Contact our team to get started today.

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AIAG DDRT Mandate for Automotive Suppliers

The Due Diligence Reporting Template (DDRT) is a standardized reporting format developed by AIAG in collaboration with leading OEMs to assess and document forced labor risk in the automotive supply chain. It’s being mandated now because voluntary compliance no longer satisfies global regulatory expectations. Governments are imposing binding due diligence laws—such as the UFLPA (U.S.), LkSG (Germany), and CSDDD (EU)—which require companies to prove they have identified and mitigated human rights risks. The DDRT provides a unified framework for OEMs to collect supplier disclosures in a consistent, auditable format, helping them meet these growing legal obligations.
Suppliers are required to report on: Corporate policy and governance: Do you have a human rights policy aligned with UNGP, ILO, and OECD guidelines? Who owns compliance oversight? Screening tools: Are you using platforms like Kharon or Altana to screen for forced labor risks in your own supply base? Facility-level risk exposure: Which regions, operations, or materials carry elevated forced labor risk? Are any linked to the UFLPA Entity List? Remediation measures: What actions were taken when risks were identified (e.g. disengagement, training, substitution, audits)? Supplier engagement: Do you collect due diligence information from your sub-tier suppliers? How often? Training programs: Are employees and key suppliers trained on forced labor awareness and compliance? Cadence of review: How frequently do you reassess risk and update your documentation? This is not an “upload and forget” form. It reflects your operating system for forced labor due diligence.
While the initial rollout targets Tier 1 suppliers, the OEMs clearly intend to extend DDRT compliance expectations down the supply chain by mid-2026. If you are a Tier 2 or 3 supplier—and especially if you source from high-risk regions or industries—you will be impacted. Tier 1s will increasingly flow down DDRT obligations through cascading contract terms to protect their own compliance posture. Don’t assume you’re exempt because you're not directly contracted by an OEM.
The UFLPA flips the burden of proof: any goods suspected of linkage to Xinjiang are presumed to involve forced labor unless the importer can prove otherwise. The DDRT requires you to demonstrate: Use of tools or databases to screen your suppliers against the UFLPA Entity List Evidence of mapping sub-tier suppliers and identifying country-of-origin risks Documentation of mitigation actions if a red flag is found DDRT isn’t just compatible with UFLPA—it’s the OEMs’ answer to ensuring their supply base doesn’t trigger enforcement action at U.S. borders.
No. The DDRT is a complement, not a replacement. Here's the distinction: CMRT (Conflict Minerals Reporting Template) focuses on 3TG materials (tin, tungsten, tantalum, gold) from conflict-affected regions. EMRT (Extended Minerals Reporting Template) expands coverage to cobalt and mica. DDRT addresses labor risks—regardless of material. If you’re supplying materials that require CMRT or EMRT disclosures, those still apply. But if you have workers in your supply chain, the DDRT applies too.
The consequences are significant and compounding: Regulatory enforcement: Your goods may be detained at borders (especially under UFLPA) or banned in the EU if connected to forced labor. Loss of business: OEMs may disqualify non-compliant suppliers from sourcing programs or discontinue contracts. Audit exposure: Incomplete documentation opens the door to targeted investigations. Brand risk: NGOs and watchdogs actively track supply chain violations—one lapse can cost long-standing reputation. DDRT non-compliance isn’t just a legal risk—it’s a commercial one.
Per the OEM mandate: Initial submission begins September 2025 for selected suppliers. Annual reporting is expected for all in-scope suppliers starting mid-2026. However, suppliers with high-risk exposure or weak documentation may be required to update more frequently—especially if red flags emerge. The smart move? Build a quarterly internal review cycle to avoid last-minute scrambles.
A DDRT-aligned system includes: A dedicated compliance owner with cross-functional authority Integration with screening platforms (e.g. Kharon, Altana) A mapped supply chain risk profile, with Tier N visibility Documented policies and escalation procedures A cadence of periodic review and reassessment The ability to generate traceable, auditable reports on demand If your current process is an Excel file buried in someone’s inbox, you are not DDRT-ready.
The AIAG Forced Labor Due Diligence Program recommends: Risk screening platforms: Kharon, Altana, Resilinc, SUPPLIERASSURANCE Training resources: AIAG’s learning pathway modules on forced labor due diligence Guiding standards: UNGPs, ILO Conventions, OECD Guidelines, and the AIAG Automotive Guiding Principles Suppliers should not improvise. These tools are what OEMs will benchmark against during evaluation.