Behind the data: What we learned assessing corporate transparency under Mandatory Human Rights due diligence laws

This contribution was written by our Program Manager, Auréliane Froehlich.

Early in 2025, Wikirate partnered with Walk Free to collect data for their report examining the transparency of disclosures under Mandatory Human Rights Due Diligence Laws (mHRDD).

The result is a report authored by Walk Free, Beyond Compliance: How to Design Effective Mandatory Human Rights Due Diligence Laws, showing that while corporate disclosures still lack transparency, stricter reporting obligations and meaningful enforcement can improve disclosure quality.

It’s easy to read a report and focus on the findings, but the work behind the numbers often goes unseen. Wikirate and Walk Free analyzed 225 corporate reports — 99 under mHRDD and 126 under Modern Slavery Acts — some hundreds of pages long, turning dense PDFs into structured, comparable data. The process was complex, time-consuming, and required careful human judgment at every step.

For us at Wikirate, this project was a humbling reminder of just how challenging it is to assess corporate human rights disclosures at scale. It requires hours of dedicated work, skill, and attention to detail. And the lessons we learned along the way — not about what, but how companies report — can also help inform the design of future due diligence laws.

The hidden work: finding corporate disclosures

Before we could begin the assessment, we first had to find the reports. That alone took a surprising amount of effort. Unlike the UK or Australian Modern Slavery Registries, where companies publish their due diligence disclosures, no such government-managed repositories existed in France, Germany, or Norway. In France, civil society created a platform to keep track of reports published under the Devoir de Vigilance (the French mHRDD law), which ended up being extremely useful.

For the rest, we had to dig, company by company.

Sometimes the reports were tucked away in obscure parts of corporate websites, buried within sustainability subpages, or lost in download centers. Other times, they weren’t posted at all, and we had to puzzle out whether the company had reported somewhere else or not reported at all.

This reinforced something we say often: transparency isn’t real transparency if the public can’t easily find the information. This is why we continue to push for public, centralized, machine-readable registries.

Turning PDFs into data: why humans still matter (a lot)

After we finally found the reports, the real work began: reading them, understanding them, and turning them into structured data. We used a methodology developed with Walk Free, building on years of experience assessing Modern Slavery Statements for the Beyond Compliance Project. This part of the project is the most time-intensive. Our team, supported by 18 Wikirate contributors (many of them students or sustainability professionals), read and evaluated every report before entering the data into Wikirate.

At this point, you might wonder: why not let AI do it? We wondered too. But in practice, extracting information from PDFs is not as easy as it seems. PDF reports are notoriously difficult to parse for LLMs, especially if they contain many complex elements such as charts, tables, and infographics, and because they do not follow a predictable structure. Another challenge is that reports are full of vague, ambiguous language that requires interpretation. A few examples:

• In corporate disclosures, the line between what companies actually did and what they might do can be blurry.
• Critical information, like the absolute number of incidents or whether cases were investigated, may be missing. Documenting those absences is key.
• Terminology varies from one company to another, so pattern-matching isn’t enough.
• And crucially, human assessors spot issues with the methodology itself and help refine it.

Although Wikirate is exploring opportunities to automate parts of the extraction process, our approach remains intentionally cautious. For this project, human-centered assessment, supported by peer review, was crucial for producing high-quality, trustworthy data.

That said, we see many opportunities for companies to make disclosures more compatible with automated processing. Publishing reports in machine-readable formats (e.g., iXBRL), tagging key information, or using standardized structures (such as those in the LkSG) and strict reporting guidelines would significantly reduce ambiguity and improve comparability.

Persistent data gaps

As we analyzed disclosures, one theme emerged consistently: reports often lacked the detail needed to understand whether modern slavery was present in the companies’ supply chain and what they are doing to respond to cases of modern slavery when it was.

Most disclosures focused on policies and vague descriptions of internal processes. These are important, but they only tell part of the story. If you’re trying to understand what a company is actually doing to prevent human rights harms, or how it responds when something goes wrong, the details often just weren’t there. Some common gaps we saw:

• Incident counts with no explanation of the nature or severity of cases.
• Grievance numbers with no breakdown of complaint types or outcomes, or broken down by categories that were too broad (“Human Rights”).
• Generic references to “stakeholders” without clarifying if workers in the supply chain were ever included or spoken to.
• Generally, a lack of distinction between what was done and what is contained in policies.

When you’re trying to build a clear picture from incomplete information, you end up making judgment calls at every turn. And if it was challenging for us as researchers reviewing several statements, it’s easy to imagine how difficult it would be for workers, regulators, or civil society to make sense of these disclosures. These gaps make it harder to know what’s actually happening in supply chains.

Improving transparency through due diligence laws

One of the lessons we take away from this project is also featured in Walk Free’s takeaways: mandatory reporting alone is not enough. We need what often ends up being forgotten about: machine-readable formats, standardized structures, centralized registries, and reporting requirements that prioritize clarity and leave little space for ambiguity. Without all of this behind-the-scenes work, corporate transparency will remain limited, and the full potential of mandatory human rights due diligence laws will go unrealized.

As policymakers refine existing laws and develop new ones while companies grapple with expanding due diligence obligations, one thing is certain: better data is necessary if we want these laws to drive real change for the people they are meant to protect.

Laws targeting modern slavery and other human rights abuses in supply chains are multiplying. Disclosure-based laws like the UK and Australian MSAs rely on corporate reporting, and the scrutiny it enables, to encourage action. Human Rights Due Diligence (HRDD) laws go further, imposing concrete obligations and requiring companies to report on how they meet them. Both types mandate disclosure, but the obligations differ significantly. This raises a key question: how does the type of law shape corporate reporting?

We conducted a comparative qualitative analysis of reports from twenty companies (or their subsidiaries) that reported under both the UK or Australian Modern Slavery Acts (MSA) and at least one European HRDD law — France’s Devoir de Vigilance (DDV), Norway’s Transparency Act (NTA), or Germany’s Supply Chain Due Diligence Act (LkSG). The companies span sectors including fashion, automotive, and electronics. Using Wikirate’s Beyond Compliance criteria, we assessed transparency across key areas: preventative measures, incident identification and remediation, whistleblowing mechanisms, and supply chain worker engagement.

Our analysis finds that reports under both disclosure-based and due diligence laws focus heavily on commitments and remain superficial when reporting actual actions and impacts, often omitting critical information such as incident reporting, remediation, and the accessibility of whistleblowing channels for supply chain workers. HRDD laws, despite stricter requirements, deliver modest improvements in transparency.

This matters because disclosures are meant to give governments, civil society, and investors insight into how companies manage modern slavery risks. When transparency is limited, stakeholders cannot assess the quality of corporate due diligence.

Do companies disclose incidents and remediation efforts?

Our analysis shows that companies that fail to report forced labour incidents under one framework usually do so under others as well: 85% reported no specific incidents under any regime. Germany’s LkSG is an exception, with reports providing comparatively more data on incidents due to the law’s prescriptive reporting requirements. HRDD reports generally include more information on the number of grievances submitted (e.g., recruitment fees, excessive working hours). However, most grievances are described imprecisely, with numbers tied to broad categories and little context on the nature or circumstances of specific violations, or whether they have been verified.

Remediation reporting shows similar inconsistencies in both depth and transparency. Patterns are stronger within companies than across jurisdictions: when a company’s MSA report is detailed, its HRDD disclosure tends to be of comparable quality. Some companies provide structured, quantitative data and clear descriptions of remedial actions, while others offer only broad or superficial statements.

This highlights an underlying tension: reporting should enhance transparency, but it can also create reputational or legal risks. As a result, disclosure could be treated as a threat rather than an opportunity. To make it meaningful, reporting should be framed as a proactive tool for accountability and improvement, not merely a compliance exercise.

Are grievance mechanisms accessible to supply chain workers?

Grievance mechanisms are essential for due diligence, yet they often remain inaccessible to supply chain workers due to language barriers, limited awareness, or the inability to identify buyer brands. Removing these barriers is crucial to ensure workers can lodge complaints and trigger remediation processes, as indicated by the UN Global Compact.

Across our sample, most companies failed to provide sufficient information on the accessibility of their grievance mechanisms or whistleblowing channels, regardless of the reporting regime. Reports rarely stated clearly that supply chain workers are entitled to file complaints, referring instead to “suppliers” or “stakeholders.” Only one-third of reports included even superficial information on how mechanisms were communicated to supply chain workers, and some shifted responsibility onto suppliers to conduct awareness-raising or put in place grievance mechanisms at the factory level. Two companies described mechanisms targeting specific worker groups — for example, migrant workers at Tier 2 suppliers in Taiwan — or reported the proportion of manufacturing sites covered by Worker Voice tools.

Do companies engage with supply chain workers?

Engagement with supply chain workers and/or their representatives is critical in helping companies identify issues that formal audits or management systems might overlook and to design more targeted remediation or preventative measures. Meaningful stakeholder engagement is a key component of internationally recognized standards such as the OECD Due Diligence Guidance for Responsible Business Conduct.

Only a small number of reports included references to engagement or maintaining regular dialogue with workers organizations or NGOs. Just five reports described specific interactions with supply chain workers. For instance, both of Samsung’s reports detailed off-site interviews with workers from nine suppliers, including migrant workers in Malaysia, while Nestlé’s MSA report outlined income diversification and training programmes in Côte d’Ivoire and Honduras.

Improving direct engagement with supply chain workers and their representatives is essential to ensure good working conditions and conduct meaningful due diligence. Companies should improve reporting on how they plan to accomplish this.

Are companies reporting on concrete actions to prevent modern slavery risks?

Preventative measures aim to address known modern slavery risks and typically include supplier vetting, employee and supplier training, auditing high-risk suppliers, and monitoring systems.

Companies varied in the range and detail of measures reported, though most disclosures were vague: generic human rights training, unclear audit conditions for high-risk suppliers, or simply restating commitment to a Supplier Code of Conduct. Compared with MSA reports, disclosures under the German Act were slightly more detailed, with two companies providing substantially more information. Comparisons with DDV and NTA reports showed less consistent patterns, with details varying largely on a company-by-company basis.

The focus on compliance undermines transparency

The gaps in reporting are striking and point to an urgent need to improve reporting quality across all jurisdictions. Weak disclosure appears consistently, even under human rights due diligence laws that require companies to establish and implement due diligence processes. These findings echo results from other research, such as Beyond Compliance, and voices within the sector showing that companies continue to approach reporting as a compliance exercise, providing only the minimum information necessary to meet legal obligations.

Although more prescriptive reporting requirements — such as structured formats and targeted questions — can encourage greater transparency, it is not clear that more stringent reporting standards will have the desired impact so long as companies do not move beyond a purely compliance-driven approach. This focus on compliance undermines the core purpose of disclosure: enabling civil society, investors, and the public to assess companies’ exposure to, and responses to, modern slavery.

Research by Ruby Jones and Zoe Jewell from the Australian National University.

The Wikirate team has reviewed the research and accompanying blog to ensure it supports our mission of providing evidence-based insights to our audience; however, the content does not necessarily reflect the views of Wikirate International.

To hold corporations accountable for their impact on people and the planet, whether it’s environmental harm or worker exploitation, changemakers need reliable, accessible data. Yet too often, this data is hard to find, locked in spreadsheets, or duplicated across siloed efforts, limiting its potential to drive real change.

That’s why Wikirate was created more than 10 years ago: to make corporate policy and impact data openly available, shareable, and actionable.

Wikirate provides two essential components to create an effective ecosystem of shared knowledge:

1. a backbone infrastructure to collect, store, and share corporate accountability data;
2. a connective tissue that fosters collaboration, interoperability, and learning.

The path forward

To continue to make a real difference, we need long-term support that allows us to scale our impact. Wikirate has collaborated on many impactful projects with civil society organizations over the past decade, and we’ve reached a pivotal moment.

In the next few years we plan to:

• Improve the infrastructure: Our open data platform, wikirate.org, is the largest open data repository of its kind. But discoverability and usability remain significant challenges. We need to improve the platform to make it easier for users to publish and find data, saving changemakers time and amplifying their impact.
• Build a collaborative global network: Data openness and interoperability are key. Right now, our team is connecting individual organizations and helping a handful of them publish their data on wikirate.org. But that’s not enough. If we want to make more corporate data open and accessible, we need to scale up these efforts. That’s why we launched ODCAN (Open Data for Corporate Accountability Network), a global initiative bringing together CSOs that use data to hold corporations accountable. By systematically weaving connections, we can ensure that organizations working on similar issues align their efforts, exchange critical data, and publish it on Wikirate.
• Gather more data beyond corporate reporting: Holding companies accountable requires more than just analyzing the reports they release. We need independent, non-company-reported data, especially supply chain data that links brands to their suppliers. Investigative journalists and CSOs have already exposed the gap between corporate commitments and real-world impact, but we must make this process faster and scalable. Wikirate provides the infrastructure to support CSOs, journalists, and investors in confronting companies with hard evidence, and sometimes even informing corporations about hidden issues in their own supply chains.
• Scale our advocacy efforts: to ensure that data on corporations is accessible, we will advocate for open data to be integrated into transparency legislation at the government level. This will ensure that more information can be made available on wikirate.org.

Open infrastructure: a strategic and urgent investment

Open infrastructure is not a “nice to have”; it’s the foundation for effective, equitable systems of accountability. Platforms like Wikirate ensure that corporate impact data remains open, interoperable, and accessible to civil society organizations, journalists, and researchers working to expose exploitation, environmental harm, and corporate greenwashing. Without robust, community-driven infrastructure, we risk a future where vital information is siloed, paywalled, or controlled by commercial actors whose priorities do not align with the public good.

This is a moment of collective responsibility. Project-based grants cannot sustain long-term operational needs. Strategic funding must support the backbone, not just the outputs, of data-driven advocacy. By investing in Wikirate, funders help build a transparent, resilient ecosystem where good ideas thrive and public-interest accountability can scale. This is not just support for a platform, it’s an investment in the future of open, democratic oversight.

Join us in accelerating change

If you or your organization is interested in supporting our open data platform and contributing to a more transparent and sustainable global economy, we would love to connect. Together, we can ensure that corporate accountability data remains a public good that is accessible to all, for the benefit of all.

We are deeply grateful to the funders and partners who have supported us on this journey so far. Their commitment to transparency and accountability has helped us build a platform that serves as a crucial resource for those advocating for a more responsible corporate world.

“At Humanity United, we see open data as critical infrastructure for responsible business practices. Wikirate is helping build that foundation — connecting the dots between civil society, corporate disclosures, and public accountability. Their work supports not only transparency, but the kind of interoperability and learning that enables systemic change.”

Katrina Gordon, Senior Manager, Forced Labor & Human Trafficking at Humanity United

“Wikirate provides an essential open data infrastructure for supply chain transparency. Their system made it possible to connect data reported by brands and workers in one dynamic tool: Fashion Checker. Through this flexible and engaging structure, we were able to make a complex dataset on supply chain wages accessible and useful to a broad audience of consumers, journalists, advocacy organizations, and workers themselves.”

Paul Roeland, Transparency Lead, Clean Clothes Campaign

“Wikirate’s open platform leverages data from its extensive network of civil society connections, helping to bridge the data gap on companies’ social performance. This enables investors to access a wealth of valuable CSO data, empowering them to make informed decisions throughout the entire investment lifecycle.”

Anita Dorret, Director, Investor Alliance for Human Rights

Donate now or get in contact with us to discuss how you can support open infrastructure for civil society today!

info@wikirate.org

14 July 2025. Wikirate has been added to the Digital Public Goods Alliance’s DPG Registry. A goal of the DPGA is to promote digital public goods in order to create a more equitable world.

Being recognised as a DPG increases the visibility, support for, and prominence of open projects that have the potential to tackle global challenges. To become a digital public good, all projects are required to meet the DPG Standard to ensure that they truly encapsulate open-source principles and what it means to be a digital public good.

Wikirate seeks to make data about corporate environmental, social, and governance (ESG) performance open, accessible, and comparable. Through a collaborative, open-source platform, Wikirate empowers citizens, companies, and organizations to collect, share, and analyse ESG data that contributes to holding companies accountable and driving corporate sustainability efforts. By facilitating access to open data and encouraging community participation, Wikirate enhances transparency and helps align corporate behaviour with the Sustainable Development Goals (SDGs).

For us, being recognised as a digital public good — defined as open source software, open data, open AI models, open standards, and open content that adhere to privacy and other applicable laws and best practices, do no harm, and help attain the SDGs — means amplifying our mission to democratize ESG data. It validates our commitment to openness, collaboration, and impact, and opens new opportunities for partnerships and scaling our efforts to drive systemic change through shared knowledge and transparency.

For any inquiries on Wikirate, please reach out to info@wikirate.org. For more information on the Digital Public Goods Alliance, please reach out to hello@digitalpublicgoods.net.

The Digital Public Goods Alliance is a multi-stakeholder initiative endorsed by the United Nations Secretary-General with the aim to facilitate the discovery, development, use of, and investment in digital public goods. Our vision is that by the year 2030, our open, collaborative, multi-stakeholder efforts have unlocked the potential of digital public goods to contribute to a more equitable world and accelerate attainment of the Sustainable Development Goals globally.

Berlin, Germany. July 10, 2025.

Wikirate International e.V., announces the launch of the Open Data for Corporate Accountability Network (ODCAN). This new initiative brings together a diverse community of civil society organizations, researchers, journalists, and other stakeholders to advance the use of open data in driving transparency, accountability, and systemic change.

ODCAN is an impact-driven network focused on improving how open data is collected, shared, and applied to hold companies accountable for their social and environmental impacts. Facilitated by Wikirate, the network offers a collaborative space to address common challenges in accessing and interpreting corporate data, while building capacity for data-driven advocacy, research, and decision-making.

Through joint data collection, peer learning, and coordinated advocacy, ODCAN supports the creation of a stronger, more interoperable open data ecosystem. Members collaborate to improve data quality, reduce duplication of effort, and amplify their collective impact. Wikirate’s open platform, wikirate.org, serves as the network’s central hub for accessing and contributing to shared datasets on corporate practices and performance.

ODCAN offers members:

1. Access to curated, high-quality corporate impact datasets
2. A global network of peers and collaborators
3. Capacity-building and learning opportunities
4. Strategic support for advocacy and campaigns
5. Tools and resources tailored to diverse use cases

ODCAN invites participation from a broad range of actors such as civil society groups, data publishers, academics, journalists, and responsible businesses, who are committed to using open data to promote transparency and accountability in corporate behaviour.

How to Join

Membership is open to organizations and individuals that publish, use, or support open data for corporate accountability. To learn more and join, visit our ODCAN site.

About Wikirate International e.V.

Wikirate International e.V. is the non-profit organization behind wikirate.org, a collaborative open data platform where a global community collects, analyzes, and shares data on companies’ social and environmental impacts. Wikirate’s mission is to empower people and organizations to freely access and use corporate impact data to promote transparency, accountability, and economic justice. The platform supports informed decision-making by civil society, workers, researchers, and investors worldwide.

“Wikirate has helped me explore corporate accountability by critically assessing how businesses report on and comply with modern slavery legislation.”

Wikirate is looking for new contributors and we’re running a campaign to celebrate the ones we’ve already worked with!

Our contributors are an indispensable part of Wikirate and give our work an extra boost to ensure that it has the greatest potential impact. Community members from around the world use our open corporate accountability data and we want to put a spotlight on their incredible work.

This week, rather than a video we have a written post by a cherished contributor, Chanelle McGuckin.

Meet Chanelle

“My name is Chanelle, and I’m from Sydney Australia. I have a background in social work and a deep commitment to combating modern slavery, a passion that grew during my time living in Thailand and through first-hand exposure to the cocoa production process in Ecuador.

Witnessing the stark imbalance — where production countries bear the greatest costs while receiving minimal benefits, often due to Western-driven demand — was profoundly unsettling.

This experience drives my determination to contribute meaningfully to addressing this human rights crisis.

Last year, I had the privilege of working with Lucía and Auréliane from Wikirate, and several other volunteers from around the world. I volunteered as a peer reviewer for the Walk Free Modern Slavery Act Beyond Compliance project. This involved reviewing the modern slavery statements of UK and Australian companies in the electronics sector. The work was coordinated seamlessly by the team at Wikirate, from the meetings to the structure of the work requirements. It was an incredible experience to collaborate with other like-minded people from all different time zones.

Wikirate has helped me explore corporate accountability by critically assessing how businesses report on and comply with modern slavery legislation. Through analysing these statements, I gained insight into both the strengths and gaps in corporate transparency.

This project showed me that while some companies are making progress, others fall short of meaningful compliance, merely performing a tick box activity, some not meeting basic requirements. It reinforced the importance of stronger regulations, ethical supply chain practices, and informed consumer choices. Individuals can drive change by supporting transparent companies, while businesses must prioritize genuine action over performative reporting.

Thanks to Wikirate again for an enjoyable and enriching opportunity!”

Feeling inspired? If you’re curious about what it’s like to contribute to Wikirate, how to get started, and the impact you can make, visit our Contributor Community Page.

Whether you’re passionate about research, data, or accountability, we’d love to have you on board. You can find our platform with millions of open corporate accountability data points here: https://wikirate.org/.

Our platform is the world’s largest open data repository focused on corporate accountability.

Sometimes the amount of data that we have can be a bit overwhelming. Want some help navigating it? We’ve got a set of guides on our platform to help you out, check them out here: https://wikirate.org/guides.

Have an exciting proposal that you want to work on with us? Reach out to us here: https://wikirate-intl.org/Contact_us

“Overall, Wikirate has helped me think critically about the systems behind the stories I tell.”

Welcome to the second installment of our series of contributor testimonies where we highlight the incredible work of our community.

Our contributors are an indispensable part of Wikirate and give our work an extra boost to ensure that it has the greatest potential impact. Community members from around the world use our open corporate accountability data, and we want to put a spotlight on their incredible work.

Meet Arun

In this blog post, we’re highlighting the work of Arun, a documentary photographer whose work focuses on worker abuse, modern slavery in global supply chains, and migrant workers separated from their loved ones.

Arun used our data to explore these issues in some of the biggest companies around the world.

Hear how Arun used Wikirate’s data in his own words:

Want to check out some of Arun’s photos? He graciously let us include some of his work in this post.

Check out his website here, keep it up Arun!

Feeling inspired? If you’re curious about what it’s like to contribute to Wikirate, how to get started, and the impact you can make, visit our Contributor Community Page.

Whether you’re passionate about research, data, or accountability, we’d love to have you on board. You can find our platform with millions of open corporate accountability data points here: https://wikirate.org/.

Our platform is the world’s largest open data repository focused on corporate accountability.

Sometimes the amount of data that we have can be a bit overwhelming. Want some help navigating it? We’ve got a set of guides on our platform to help you out, check them out here: https://wikirate.org/guides.

Have an exciting proposal that you want to work on with us? Reach out to us here: https://wikirate-intl.org/Contact_us

“It was especially interesting to see how this research contributes to wider reporting and accountability.”

Welcome to our series of contributor testimonies, where we highlight the incredible work of the Wikirate community.

Our contributors are an indispensable part of Wikirate and give our work an extra boost to ensure that it has the greatest potential impact. Community members from around the world use our open corporate accountability data, and we want to put a spotlight on their incredible work.

Meet Bella

In this blog post, we’re celebrating Bella who collaborated with us on our Beyond Compliance project with Walk Free.

Bella is currently studying a law degree, and as a volunteer she helped us assess the modern slavery statements of some of the world’s largest and most influential electronics companies.

Hear how Bella experienced contributing to Wikirate in her own words:

Feeling inspired? If you’re curious about what it’s like to be a Wikirate contributor, how to get started, and the impact you can make, visit our Contributor Community Page.

Whether you’re passionate about research, data, or accountability, we’d love to have you on board. You can find our platform with millions of open corporate accountability data points here: https://wikirate.org/.

Our platform is the world’s largest open data repository focused on corporate accountability.

Sometimes the amount of data that we have can be a bit overwhelming. Want some help navigating it? We’ve got a set of guides on our platform to help you out, check them out here: https://wikirate.org/guides.

Have an exciting proposal that you want to work on with us? Reach out to us here: https://wikirate-intl.org/Contact_us

The electronics industry is booming — and it’s not slowing down anytime soon. The consumer electronics market alone is projected to surpass $1 trillion by 2030, while the push for renewable energy and electric vehicles (EVs) continues to accelerate. Digitalization and the green transition are driving this surge in demand, and it may seem like a step in the right direction. But there’s a catch.

Behind every smartphone, laptop, and electric vehicle battery, there is an often forgotten but essential component: critical minerals like silicon, cobalt, lithium, and rare earth elements (REEs). As demand for electronics and green energy technology soars, so does the need for these minerals. But their extraction comes with significant environmental and social consequences, ranging from habitat destruction, pollution, exploitation, human rights violations, conflicts, and political instability –all of which have already claimed too many lives and livelihoods in countries like the Democratic Republic of the Congo.

The pressure to reduce reliance on newly mined materials has never been greater. Recycling critical minerals should be at the heart of this effort. But are electronics companies truly embracing the circular economy?

We analyzed the sustainability disclosures of 30 major electronics companies to find out how much information they provide about recycled minerals. We looked for publicly available information about the amount of minerals recycled, the companies’ targets for recycling, and the minerals that were mentioned.

Do companies disclose how much they recycle, or are they keeping us in the dark?

What are the reporting requirements for recycled minerals?

Currently, most corporate disclosures related to minerals focus on conflict minerals — such as tin, tungsten, tantalum, and gold (3TG) — rather than recycled materials. The companies we looked at typically reference three regulatory frameworks in their reports:

• The Securities Exchange Act of 1934 (17 CFR 240.13p-1)
• The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
• The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

The EU Conflict Minerals Regulation could also lead to voluntary reporting from companies, although it was not mentioned as the basis for reporting.

These frameworks are designed to prevent minerals from financing armed conflicts and human rights abuses, but they don’t require companies to report on recycled minerals. Instead, companies voluntarily disclose data on recycled minerals, often as a secondary way to limit the use of conflict minerals.

The Corporate Sustainability Reporting Directive (CSRD) and the associated reporting standards ESRS E5 Resources Use and Circular Economy are expected to introduce more standardization in reporting recycling practices. However, at this stage, reporting on recycled minerals remains largely voluntary and inconsistent.

How do companies disclose their mineral recycling practices?

We found that while most companies mention recycling and minerals, their disclosures lack consistency and clarity. Here are two key challenges:

1. No standardized reporting across companies

Each company defines its own metrics, making comparisons difficult. Some indicators appear in the reports of multiple companies, but there is no consistent reporting pattern. For example, companies disclose:

• Tonnes of electronic products, e-waste, or minerals recycled
• Percentage of materials in products coming from recycled sources
• Percentage increase in recycling of specific minerals (e.g., gold)
• Percentage of products sold to customers containing recycled minerals
• Percentage of manufacturing waste upcycled
• Number of components saved from landfills
• Number of devices recycled
• Overall recycling rate
• Tonnes of Post-Industrial Recycled (PIR) metals

The lack of uniformity in reporting poses significant difficulties for anyone trying to compare companies’ recycling practices or understand how sectors, such as electronics, are changing over time.

2. Lack of specific data on critical minerals

Most companies report on recycling in aggregate terms, mentioning categories like “devices,” “e-waste,” or “components” without breaking down the specific minerals being recovered. Figures such as the recycling rate or percentage of products recycled also fail to provide the necessary information. This lack of detail obscures the reality of their recycling efforts.

For example, one company may report that 14 million hardware components were recycled — but if that only includes plastic casings and steel screws, it tells us nothing about whether critical minerals like lithium or cobalt are being reused. Only a few companies provided specific figures on recycled minerals like tantalum or gold.

This lack of transparency makes it nearly impossible for stakeholders to assess whether companies are truly “closing the loop” on critical raw materials.

Why we need stricter reporting requirements

The gaps in disclosure leave civil society, investors, and policymakers without a clear picture of corporate recycling practices. Without reliable data, it is impossible to differentiate between companies making real efforts and those engaging in greenwashing rather than genuine action. The lack of standardized reporting makes it easy for companies to overstate their commitment to circularity.

Given the environmental destruction caused by mining and the finite supply of critical minerals, recycling should be a top priority for industries like electronics and renewable energy. Public oversight is essential to drive meaningful change.

The CSRD’s reporting requirements include indicators on resource use and circularity (ESRS 5), which, if companies choose to report on recycling minerals specifically, could lead to more transparency on minerals recycling practices. However, the recent Omnibus proposal threatens to discard some of those requirements, which would mean maintaining the status quo. And the truth is that without mandatory, granular reporting on recycled minerals, many companies will continue operating in obscurity.

Stronger global reporting standards on critical mineral recycling are urgently needed. In the end, it is about stopping the human suffering and environmental damage that comes with the world’s growing appetite for technology. We urge companies to implement the ESRS 5 reporting standards when preparing disclosures in relation to resource use, and on minerals in particular, no matter whether the relevant ESRS standards are maintained in CSRD.

Do you want to join us in calling for more transparency on minerals recycling? Share this article and get in touch with Aureliane at aureliane@wikirate.org. We welcome partnerships with civil society, academia, journalists, and businesses.

This article was co-written by Wikirate contributor Nabilla Khansa Naura, Business and Human Rights Practitioner, and Aureliane Frohlich, Program manager at Wikirate.

On March 12th, Wikirate hosted an event as part of the 15th annual Open Data Day celebrations. Throughout the event, three speakers discussed how data shapes their work, the challenges of accessing corporate transparency information, and the evolving role of open data in advocacy.

The speakers included:

• Laura Ranca from Tactical Tech’s Exposing the Invisible project, focuses on open-source research and corporate investigations;
• Kate Jelly from the Business & Human Rights Resource Centre (BHRRC), who specializes in labor rights within global supply chains;
• Luís Costa from the World Benchmarking Alliance, (WBA) who leads research on climate impacts and energy transitions.

Corporate-reported data remains an essential resource

With the turbulent environment for corporate accountability and sustainability in mind, the discussion highlighted that despite its flaws, corporate-reported data remains a crucial resource for advocates and researchers. It provides insight into company behavior, enables performance comparisons and, when used strategically, can reveal inconsistencies between what companies say and what they do.

Kate Jelly from the BHRRC highlighted that in the garment industry, the Rana Plaza tragedy catalyzed a push for greater transparency across the sector, resulting in companies voluntarily disclosing supplier lists. This data has been vital in connecting suppliers to buyers, which has helped advocates such as the BHRRC push for better labor standards for garment workers.

Laura Ranca from Tactical Tech highlighted how regulations can serve to improve corporate transparency. Specifically, she mentioned the Digital Services Act, which defines corporate responsibilities and obligations to ensure that digital services are safe for users. She mentioned that regulations like these help to set a baseline in terms of what rules companies must follow and the data they have to release to show compliance. In turn, this lets journalists, activists, investors, and advocates assess whether this data indicates that companies are fulfilling the requirements set out in the regulations.

Luís Costa from WBA mentioned that self-reported data can give insight into the extent to which companies consider ESG topics and how that measures up to their actual behavior. He and his team compared investment data on renewables to company disclosures and found a significant gap between actual investments and stated goals. While companies declared meaningful investments in renewables within the heavy-industry sector, actual efforts fell short. Taking it one step further, he and his colleagues were able to show that if companies adopted best practices and shared knowledge, climate targets and sustainable investment goals would be achievable.

Where corporate-reported data falls short

All three speakers agreed that corporate-reported data comes with serious limitations. Voluntary disclosures are often selective, inconsistent, and biased. Frequently, companies withhold data under the guise of competition, often in areas where transparency is most needed such as in labor conditions, emissions, and supply chain risks. For example, we found that recent data indicates a severe underreporting of modern slavery and labor violations throughout supply chains — highlighting that even though reporting obligations exist, companies frequently fail to disclose cases of abuse.

This can result in what’s called the “disclosure paradox” where companies are incentivized to be less transparent about potential violations. In this situation, companies that voluntarily disclose more information are at a greater risk of reputational damage. On the other hand, companies who are more opaque and fail to report don’t face the same scrutiny and have less reputational risk. This paradox likely contributes to the systematic underreporting of violations, meaning that we don’t know the true volume of abuse taking place.

Another issue with voluntary disclosures for company-reported data is that too often, it takes a tragedy to usher in the will to change policies and promote transparency. Waiting for a crisis like the Rana Plaza disaster to force transparency is a failure of responsibility; businesses must proactively disclose critical information to prevent harm, rather than responding only when disaster strikes. Civil society and other stakeholders should work together to influence companies to disclose more information, especially around supply chains where risks are highest and harm is most prevalent.

Civil society as the driving force despite headwinds

While political and other key actors are rolling back commitments to protect people and the planet across the world, civil society has an even more important role to play to achieve greater transparency.

Our panel reflected that it’s the role of CSOs to continue to fight for increased and effective regulation, and that we must find a way to keep the pressure on ourselves.

The discussion highlighted some key strategies to keep pushing for corporate accountability:

1. Leveraging competition: Benchmarks and rankings incentivize companies to improve disclosure as they seek a stronger public image.
2. Recognizing transparency efforts: Acknowledging companies that are more transparent, even when it reveals more incidents, is crucial. This approach highlights accountability rather than assuming that other companies are free of wrongdoing.
3. Capitalizing on high-visibility moments BUT not relying on them: In the past, major events have drawn public attention to corporate practices, however, we shouldn’t rely on such events to increase transparency.
4. Strengthening regulation: Robust policies and frameworks are essential to move beyond voluntary disclosures and establish transparency as a standard practice.
5. Collaborative efforts: Civil society, journalists, trade unions, and workers can collectively amplify pressure on companies.
6. Consumer and investor pressure: Demand for higher transparency standards from consumers and investors plays a significant role in pushing for change.

Open Data Day provides a rare and valuable space for researchers, activists, and civil society to come together, exchange knowledge, and build stronger alliances. These gatherings foster collaboration across sectors, helping participants identify shared challenges and co-develop solutions.

Beyond promoting access to data, Open Data Day highlights the importance of people working behind the scenes: those who use data to expose injustices, challenge power, and advocate for a more transparent, accountable world. By sharing methodologies, tools, and success stories, events like this contribute to a growing movement that demands better from business and better protections for people and the planet.