Human rights, civic space, democratic institutions and the rule of law are under mounting pressure across the globe and in the US. Global business uncertainty and hardening anti-ESG sentiment are compounded by risk of government and business action targeting civil society, companies and individuals who speak out in support of rights. Together, these pressures damage stable, predictable rights-respecting operating environments that are critical for business sustainability and long-term profitability. In an October 2025 poll, 84% of senior business leaders reported being “very or somewhat concerned about the current political and legal climate’s impact on their companies.”

Against this background, this analysis – an update to the Business and Human Rights Centre’s (BHRC) initial findings on top US companies’ commitment to human rights, published in November 2025 – examines how these firms are navigating the current environment. While the November 2025 analysis found broad continuity in corporate human rights commitments, this update reveals a more mixed picture in corporate practice. Why should business still prioritize human rights?

Put simply, respect for human rights in business still makes sense. Responsible business conduct is still required by many national and international standards and regulations. It’s still expected by stakeholders, and investment in human rights can help improve worker productivity and ensure long term business sustainability. In other words, investing in human rights has proven time and again to be good for the long-term bottom line.

History highlights that periods of anti-ESG sentiment and uncertainty are neither linear nor permanent. A recent PwC briefing noted that “[a] mistake to avoid in moments like this is to read uneven enforcement as a lasting retreat, rather than a cycle that resets quickly when events force the issue.” It can be costly for business to rebuild what has been rolled back when political tides change.

Companies should also remain attentive to the durable forces that continue to drive responsible business conduct – a counterweight to the current pressure to retreat. In addition to recent advances in human rights due diligence regulation in Europe, Africa, Asia, Latin America and Canada, indicators of momentum toward a rights-respecting economy include:

• Growing legal accountability for corporate human rights impacts. Courts continue to hold companies accountable for harms linked to their operations and products. In March, juries found Meta liable in cases in California and New Mexico concerning youth mental health, platform safety and consumer protection, resulting in significant financial damages and market consequences. In February, Dyson reached a settlement agreement with migrant workers after a UK court allowed their forced labor lawsuit to proceed, a case described by some as a milestone decision for corporate accountability in global supply chains. In April 2022, BHRC invited Dyson to respond to the allegations raised before litigation commenced; it did not respond.In France, courts found the Yves Rocher Group liableunder the duty of vigilance law for harms linked to its operations in Turkey – the first such ruling against a French company for cross-border abuses. Courts there also convicted cement manufacturer Lafarge and former executives on charges of financing terrorism and violating international sanctions, in a case widely viewed as a landmark for corporate legal accountability.
• Investors expecting strong ESG performance. As one example, in March nearly 100 institutional investors called on companies to uphold the rights of immigrant workers amid mass deportations in the US. During the 2025 proxy season, when faced with shareholder resolutions attacking DEI, “approximately 98% of the shares voted to maintain corporate diversity, equity, and inclusion programs.”
• Consumers demanding that brands respect and defend the rule of law. Companies have faced powerful pressure to oppose ICE immigration raids, while OpenAI saw a reported increase in uninstalls of ChatGPT of 295% following its agreement with the US administration to provide AI capabilities for defense applications. The deal raised concerns about military uses of AI, surveillance, and lack of safeguards governing deployment. OpenAI said the company “think[s] [its] agreement has more guardrails than any previous agreement for classified AI deployments” and that the US Department of War made clear that OpenAI’s tools will not be used for domestic surveillance.
• Employees challenging corporate practices. In April, a former Thomson Reuters employee sued the company, alleging wrongful termination after raising concerns about ICE’s use of its technology. Thomson Reuters said it “take[s] employee concerns seriously and provide[s] clear channels for colleagues to raise issues. [The company] strongly dispute[s] the allegations and intend to robustly defend the case.” In March, OpenAI’s robotics lead resigned over concerns about surveillance and autonomous weapons amid the company’s Pentagon contract.
• Community opposition to abuse disrupting business operations. Examples of protests, litigation, court orders and project shut-downs linked to alleged human rights and environmental harms affecting major transition mineral mining projects are on the rise. They include the Balama graphite operation in Mozambique, the Cobre Panama copper mine in Panama, and the Jadar lithium mine in Serbia. Similar tensions are emerging around data center development, reflecting growing public expectations that companies meaningfully address human rights abuse and injustice.

Challenges to human rights and environmental standards may be more visible at this moment, but the evidence above demonstrates the existence of durable counter-pressures driving respect for rights over the long term.

Pathway 1: Big Oil and Big Tech are aggressively pursuing deregulation, to the peril of human rights and democracy

Big Oil and Big Tech, the largest and most influential firms in these key sectors, stand out for their use of this moment to aggressively lobby against responsible business regulation. Their actions pose a serious threat to human rights and democracy around the world and set a concerning precedent.

Big Oil is systematically undermining regulatory protections and civic space

In our November analysis, we highlighted reporting by SOMO on the role ExxonMobil allegedly played in weakening the EU Corporate Sustainability Due Diligence Directive (CSDDD). BHRC invited ExxonMobil to respond, it did not.

In December 2025, SOMO further reported, based on leaked documents, that a coalition of 11companies – primarily US fossil fuel firms including Chevron, ExxonMobil and Koch, Inc. – allegedly worked through a "Competitiveness Roundtable” to undermine the Directive. SOMO invited the Roundtable companies to respond. Key provisions of the CSDDD were subsequently removed, including requirements to adopt climate transition plans and an EU-wide harmonized civil liability regime were cut, while the number of companies covered was “drastically reduced” . Despite significant rollbacks, the CSDDD remains a landmark law that strengthens avenues for affected communities to engage companies, pursue corporate accountability and seek justice.

In the US, fossil fuel companies have lobbied for bills that would criminalize opposition to their projects, building on legislation already enacted in 19 states, limiting protests at pipelines or critical infrastructure sites. This legislation targets free speech and the right to dissent, making it more difficult for affected communities to raise concerns about projects that may threaten their health and livelihoods.

Energy Transfer’s lawsuit against Greenpeace, widely viewed as bearing the hallmarks of a strategic lawsuit against public participation (SLAPP), exemplifies efforts to restrict opposition to fossil fuel projects. In March 2025, a North Dakota jury found Greenpeace liable for claims linked to protests led by Indigenous Peoples against the Dakota Access Pipeline, resulting in a USD345m judgment against Greenpeace. Independent trial monitors warned that the “jury verdict was the result of an unfair trial and sets a dangerous precedent for human rights.” Greenpeace said it would seek a new trial and appeal the decision if necessary. In May 2025, BHRC invited Energy Transfer to respond; the company’s full response is available here.

The fossil fuel industry has also been lobbying Congress for “permitting reform” that would remove foundational environmental safeguards, with the effect of reducing the rigor and scope of the National Environmental Policy Act (NEPA) and the Clean Water Act (CWA). The proposed legislation directly mirrors elements of the American Petroleum Institute’s policy plan. Big Oil is also pursuing immunity from climate liability lawsuits and related measures at the federal and state levels. Climate immunity legislation was recently introduced in Congress, and in March, Utah enacted a law shielding companies from climate related claims, becoming the first state to do so. Tennessee, Oklahoma and Iowa followed in April and May, and Republican lawmakers in at least several other states are working on similar measures. From a human rights perspective, such environmental protections and channels for corporate accountability for climate impacts are critical for the realization of the right to a healthy environment.

Big Tech unleashed

Tech companies – most of which are based in the US – are lobbying in the country and around the world to shape digital rules in their favor on topics such as AI, social media, data privacy, data centers and the rights of platform workers. SOMO provides a systematic disclosure of industry efforts in the US, Australia, Brazil, the EU, India and Kenya, highlighting that companies have been particularly effective in their lobbying in part because of their control of global communication infrastructure: “By owning the way people access and share information, Big Tech is in a position to threaten governments and shape the environment in which public debate happens.” Of particular note, as we set out in our November analysis, has been the sector’s shift in overall sentiment on AI regulation. In 2023, major tech firms made voluntary commitments to “advance a generative AI legal and policy regime,” pledging to follow them until formal regulations arrived; today, the industry is most recently accused of pressuring the EU to “water down” its landmark Artificial Intelligence Act.

Big Tech’s ability to influence regulations comes at a time of increasing weaponization of technology against civic space. Companies develop, sell, and maintain the systems used by state and non-state actors to monitor, profile, and suppress activists, journalists, trade unionists and community leaders. Amnesty International’s investigation into the repression of Gen Z–led protests in Kenya, for instance, documents how authorities deployed social media monitoring, digital surveillance and online harassment to identify protesters, spread disinformation and justify arrests.

In addition, there are still few rules governing who can access and use powerful surveillance technologies, and even fewer mechanisms to enforce those that exist. While companies routinely claim that they only sell surveillance technologies “to democracies” and that they “comply with local laws,” documented evidence shows that these assurances do not prevent or mitigate harm. Only 7% of the world's population currently lives in liberal democracies, highlighting the need for companies to update and extend the scope of their human rights due diligence processes.

This combination of companies writing their own rules, and multiple voluntary and mandatory efforts failing to prevent technologies from being used in ways that threaten civic space and human rights, poses a fundamental danger to democratic governance and the public interest.

Pathway 2: A silent retreat

Many companies are less visible and vocal in their retreat from human rights commitments than Big Oil and Big Tech. Some companies - including longstanding leaders on human rights - have quietly pulled back investments in human rights staff, consultants, and initiatives or reduced the scope of their human rights programs. Survey results highlight that this reduction in capacity threatens to undermine the integrity and credibility of these companies’ commitments to respect human rights, even where these policies remain in place.

There are numerous forces driving this silent retreat. Most survey respondents identified more than one factor, including the shifting political or regulatory environment outside of the US (named by 40 individuals and six company respondents), especially the CSDDD; organizational cost-cutting (38 individuals and four companies); the changing US context (30 individuals and four company respondents); and varying priorities of company leadership (32 individuals and one company).

Changing leadership priorities present a familiar challenge for business and human rights practitioners within companies. As several experts reported to BHRC, those working on human rights within companies spent considerable effort over many years successfully making the business case for investment in human rights policies and practices. Many had since secured those commitments and moved on to implementation. Now, practitioners are again needing to make the business case for these policy commitments and especially implementation efforts as company priorities shift amidst real and perceived external pressures.

When companies scale back their human rights programs, their ability to identify, prevent and remedy human rights harms diminishes. This backtracking increases risks to the business and leaves companies less prepared to comply with future regulations or pivot back when political tides change. Here are some of the ways companies are silently retreating.

According to survey results, several large companies and consultancies have cut human rights teams and budgets

From our survey results, it is reasonable to conclude that several major US companies have meaningfully cut human rights teams, budgets and/or consultants since November 2024 – to the extent that their capacity to implement core policy commitments may be undermined or at risk. Other sources have also noted some companies downsizing teams and budgets focused on corporate responsibility, ESG or sustainability initiatives.

Before presenting our data on cuts, it is critical to note that not all companies are downsizing on human rights. Among the top US companies that responded to our survey, the majority (eight of the 13) reported team size holding steady or increasing. Ten of the 13 reported budgets holding steady or increasing. In addition, change in team size is not an exact measure of change to a company’s capacity to implement its human rights commitments. In fact, in conversations, at least one company indicated that human rights is so embedded within the organization that engineers and other operations staff are eyes and ears for human rights risks. That said, such information is difficult to obtain from the outside, and looking at reductions in team size can be a telling proxy for rollback in human rights commitments and/or implementation.

Of the 13 companies that responded to our survey, five reported reduced staff. Most did not report the number of staff cuts, but for one company, the decrease was close to 30%. Three reported decreased budgets for human rights work, one by 40%.

In addition to findings from companies, 11 individuals previously working for US companies – including some of the largest US companies in multiple sectors – and 21 individuals previously working with companies based in the rest of the world reported leaving or losing human-rights related positions. Most reported cuts by their former employer beyond their own roles.

Among individuals who recently left or lost human rights-related positions at US-based companies,  nearly three quarters (8) reported that their former employers had decreased the number of staff working on human rights by more than 20%.

Many of these individuals (19) also reported that their former employers had cut human rights budgets. While many did not know the percentage reduction, one individual who previously worked with a large multinational semiconductor company reported budget for human rights work had been reduced somewhere in the range of 50-75%.

As some major companies cut human rights teams and/or budgets, so, reportedly, have several consulting firms whose staff support corporate human rights work. Twenty-six respondents to our survey were professionals who had recently left roles at consultancies or advisory firms. Eight have more than 11 years of experience; ten have between six and ten years. The majority reported staff cuts beyond themselves, and 62% reported decreases by 20% or more. Among the previous employers were at least four of the large and mainstream consulting firms and several boutique groups.

As for the reasons why, several respondents described demand for their services drying up. They reported a “lack of corporate clients”, “less projects”, projects being “discontinued”, there simply being “no more projects”, a “reduction in client demand,” and “limited chargeable work from an advisory perspective for this field of work”. Eighteen individuals reported that their organizations had undergone budget cuts affecting its human rights function or services during 2025 or 2026. Fifteen reported that their organization had shifted the focus or scope of its human rights efforts, with some describing shifts away from explicit human rights work toward broader ESG, sustainability, and DEI efforts.  Most (nearly 70%) cited regulatory changes or regulatory uncertainty as a driver.

Other reductions in the business and human rights ecosystem

An additional set of respondents to our survey of people who had recently left or lost human rights roles were previously with ESG research and data providers – key providers of data for human rights due diligence processes for many companies and investors. One respondent from a major provider estimated that the number of people working on human rights had declined by 90%. The risk is that investors and companies that rely on them will make consequential decisions based on incomplete data. Such gaps, in turn, increase the risk of overlooking or minimizing human rights risks.

Other survey respondents included individuals from financial institutions, asset managers, a certification body and a trade association. One, recently laid off from an anonymous European bank, reported a 93% decrease in staff working on human rights. These examples suggest a trend of diminished commitment to, prioritization of, or interest in mainstreaming human rights due diligence.

Several US companies have reportedly changed the focus or scope of their human rights efforts since November 2024, moving from “ambitious” to “compliance-based” approaches

Seven top US companies, eight individuals who previously worked at US companies, and 11 individuals who previously worked at companies based in the rest of the world reported that the focus or scope of the company’s human rights efforts had changed since November 2024. Many of the individual respondents noted that their former employer had pulled back from ambitious human rights programs to focus instead on minimum compliance. In addition, some respondents (from both surveys) indicated that human rights work had been absorbed into or was now controlled by legal teams.

Based on the limited data we have, we cannot determine the impact of the shift toward compliance-based approaches, including what human rights work may no longer be undertaken and the implications for workers and communities. As one respondent observed, “Changes to human rights priorities would be hard to see from outside the company.”

Big US agribusinesses, through their industry association, left the Brazil soy moratorium

In January, the Brazilian Association of Vegetable Oil Industries (ABIOVE) which represents 18 companies including US-based Cargill, ADM, and Bunge – withdrew from the Amazon Soy Moratorium. The soy moratorium, which has been credited with significantly reducing deforestation in monitored municipalities, is a voluntary agreement under which companies commit to not purchase soy grown in areas of the Amazon deforested since 2008. Reports estimate that, with the traders’ exit from the pact, deforestation may rise by 30%. Indigenous leaders are also concerned about pollution and invasions of lands. Leading European retailers have sent an open letter to major soy traders pushing for safeguards to ensure future soy production is not linked to deforestation.

BHRC invited ABIOVE, Cargill, ADM, and Bunge to respond. All responded, see here. ABIOVE’s response is available here; Cargill’s here; ADM stated that ABIOVE was responding on its behalf; Bunge’s is here.

Apparel buyers’ limited transparency on tariff-related human rights risks

Tariffs imposed by the US in 2025 have significantly disrupted global garment supply chains, with workers bearing much of the burden. Reports from suppliers, unions and industry groups indicate that as buyers moved rapidly to reassess sourcing strategies and production costs, suppliers experienced orders being paused or cancelled, sourcing locations reconsidered and price reductions requested.

Failures in human rights due diligence and buyer decision-making that appeared to pass all burden to suppliers and workers translated into labor impacts across producing regions, including factory closures, layoffs, reduced working hours, price cuts and delayed payments. Women and migrant workers were particularly exposed due to precarious employment and limited social protections, facing food insecurity, loss of access to life- saving medicine and heightened risks of trafficking and survival sex.

Despite widespread human rights implications, corporate transparency was absent. None of the 25 apparel buyers – 18 of them US-based – contacted by BHRC responded to requests for information on how sourcing changes were managed or whether labor impacts were assessed.

A small number of companies have reduced sustainability reporting; a larger number have reduced LGBTQIA+ workplace equality reporting

Reporting on human rights risks and impacts is expected by regulators, investors, civil society and others, and the reporting process can foster meaningful internal and external engagements that strengthen a company’s approach to human rights. Some companies publish standalone human rights reports; many integrate human rights reporting into broader sustainability reports.

Among Russell 3000 companies, there was a 17% decline in sustainability reports published in 2025 compared to 2024. Encouragingly, most large companies continued to report: among the S&P 500, reporting fell by just 4%, with companies like Apple continuing to publish detailed human rights reports. The Lead the Charge Coalition noted that General Motors was the only automotive company featured in its electric vehicle benchmark that did not publish a sustainability report in 2025. General Motors did publish a human rights statement later in 2025 after the Leaderboard’s data cut-off date, as well as a Task Force on Climate-related Financial Disclosures Report.

The decline in reporting was sharper on LGBTQIA+ workplace equality. According to the Human Rights Campaign’s State of the Workplace for LGBTQ+ Americans and Corporate Equality Index (CEI) 2026, fewer employers chose to document practices through their CEI submissions than in past years. Among Fortune 500 companies, there was a 65% decline, from 377 participants in 2025 to 131 this year. Changes in reporting on gender and DEI more broadly are areas for possible future research.

Pathway 3: Staying the course

Despite some business actors engaging in aggressive lobbying or quietly retreating, many companies are still holding firm on human rights policy commitments and implementation capacity under significant pressure. Some are taking encouraging action, showing that corporate respect for human rights is still possible in today’s context.

Most top companies are maintaining commitments

Many companies appear to be maintaining their human rights commitments. Several human rights-related benchmarks (KnowTheChain, Corporate Human Rights Benchmark, Social Index, Leaderboard) published so far in 2026 confirm that by and large, assessed US companies with human rights policies and commitments have at least maintained them. Moreover, there are no reported withdrawals from the Voluntary Principles on Security and Human Rights/VPI (extractives) or the Global Network Initiative/GNI (tech), two of the major multi-stakeholder initiatives that establish sector-wide standards on specific human rights issues and risks.

Some companies are maintaining, or even growing, human rights headcount

Noteworthy despite the small sample size, four of the 13 companies that responded to our survey have increased the number of people working on human rights full-time or part-time since November 2024, and four maintained current levels.

The vast majority – with concerning exceptions – of public companies are still allowing shareholder votes on ESG issues

In November 2025, the SEC staff announced it would no longer make determinations on whether companies' challenges to shareholder resolutions were valid. This change has made it easier for companies to omit shareholder resolutions from their proxy statements for a vote. Historically, upon receiving a request from a company to omit a resolution, SEC staff would analyze both sides of the argument and then issue its decision. Now, a company sends a letter informing the SEC of its intent to exclude a proposal and the SEC simply responds with “no objection”, as long as the company has stated that it has a “reasonable basis” for exclusion.

A fear among ESG investors is that this change would lead to many companies unilaterally omitting proposals, “muzzling shareholders” trying to raise important ESG issues. But that hasn’t played out to the degree feared: “The vast majority of companies receiving resolutions did not challenge the resolutions submitted,” according to recent analysis from the Interfaith Center of Corporate Responsibility (ICCR). ICCR further notes that the number of challenges this year (37 on ESG proposals) is not significantly different from past years. Among the companies that chose to utilize this no-objection process, some still engaged in dialogue with investors and reached meaningful agreements that led to the resolution’s withdrawal. For most companies, the 2026 ESG proxy season has been business as usual.

But a small number of companies including Amazon and Dell have been singled out by ICCR as companies that they “believe are behaving opportunistically by offering weak or meritless arguments to support their announcements that they intend to exclude proposals, as analyzed by lawyers who specialize in this area of law.” We asked Amazon and Dell to respond. Amazon's response is here. Dell did not respond.

In addition, six companies are facing lawsuits from resolution proponents challenging exclusions, of which three have been settled to date.

There have been some examples of companies speaking out against attacks on democracy and the rule of law

Very few companies are speaking out against attacks on democracy and the rule of law, despite these being necessary conditions for stable and predictable business environments. An October 2025 poll found that over a third (36%) of business leaders felt “very uncomfortable or somewhat uncomfortable publicly expressing their views on government policy”, fearing political retribution and reputational risk.

Nevertheless, examples of better practice do exist. An open letter by 60 chief executives of Minnesota-based companies, notably including Cargill, General Mills and Target, issued by the Minnesota Chamber of Commerce on 25 January, was published following the shooting of Alex Pretti by a US federal agent in Minnesota. The letter called for “an immediate de-escalation of tensions” although it was criticized by human rights advocates for its refrain from explicitly calling for a full withdrawal of ICE from Minneapolis or for accountability for the murders of Pretti as well as Rene Good. The letter also disclosed that the companies had been engaging behind the scenes with the White House. Tim Cook, CEO of Apple, also called for “de-escalation” and told employees he was “heartbroken” and had shared his views with the President. Sam Altman, CEO of OpenAI, also reportedly expressed to staff that “what’s happening with ICE is going too far.” Altman also joined with NVIDIA CEO Jensen Huang and Salesforce CEO Marc Benioff along with San Francisco Mayor Daniel Lurie to persuade the Administration not to deploy National Guard troops in the city last October 2025.

The American Sustainable Business Network (ASBN), which represents small businesses, issued a statement that went further than many companies, “We demand a nation where safety is rooted in justice, not fear.... The private sector has a responsibility to speak out when democracy is under threat. Silence is not neutral. Silence enables erosion of our rights and our economy.”

Engagement by corporate leaders in defense of the rule of law can be a source of important leverage for change in today’s context. Speaking out together, such as through industry associations, can offer some protection to individual companies. But as the ASBN warned, silence itself carries a cost.

Tech companies took some limited steps toward respect for human rights

While many of Big Tech’s actions are posing a threat to human rights and democracy, there are still some examples of tech companies taking limited steps toward – or in defense of – respect for rights. In February, Anthropic refused to grant the US Government unrestricted access to its systems, requesting guardrails related to autonomous weapons targeting and mass domestic surveillance. Anthropic sued when the Administration responded by deeming the company a national security risk. Microsoft filed an amicus brief in support of Anthropic; several additional tech companies also signed on to a brief.

Other examples include 13 technology companies, including both Fortune 500 companies and smaller innovators, working on guidance for the industry on human rights Key Performance Indicators, and recent changes across Microsoft platforms' maps ensuring the inclusion of Palestinian geographic references.

Where next?

Human rights risks and responsibilities continue to confront business across communities and workplaces around the world – while complex new risks expand from tech and AI to regional and geopolitical conflicts.

The mixed picture that emerges from companies’ responses to the turbulent political and economic landscape poses serious concerns about the future of corporate human rights practice. The risk of both aggressive attacks on progress and quiet, incremental retreat is significant, and silence is not a neutral choice. At the same time, companies holding the line – and in some cases pushing forward – show that the business and human rights agenda can both withstand current pressures and remain necessary to address the crises we collectively face. Corporate respect for human rights is still possible in today’s context.

Despite the uncertainty, the significant if insufficient progress built over two decades can be protected. We can do this by supporting the companies holding firm to their human rights commitments and programs – while encouraging them to go further; exposing those silently retreating; and countering those working aggressively to dilute human rights commitments and dismantle protections.