For World Cup 2026, FIFA is integrating a multi-step human rights due diligence process, which was a prerequisite for cities interested in becoming Host Cities. But these requirements do not affect just the cities. As FIFA moves forward with preparations for World Cup 2026, compliance with the obligations undertaken in the human rights due diligence process will be key for companies seeking to become stakeholders at any level in the event. Given the size and scope of the World Cup tournament, FIFA’s approach may present a new paradigm for large scale, multi-jurisdictional human rights due diligence.
FIFA Human Rights Due Diligence Process
During the Host City selection process, FIFA implemented new human rights requirements for the tournament. These requirements included submission of the following materials:
- A “Host City Human Rights Declarations” in which each then-candidate city committed to respect, protect, and fulfill human rights in all activities associated with the hosting of the FWC 2026, and to support FIFA in implementing their operations in accordance with the UN Guiding Principles on Business and Human Rights (UNGPs) and FIFA’s own human rights commitment.
- A human rights strategy for the competition, including a comprehensive report identifying and assessing any risk of adverse human rights impacts in connection with the hosting and staging of the competition, including legacy and post-event related activities;
- Commissioning of an independent study assessing how the national context, including the national legislation and legal practice, may impede or enable the member association’s ability to host and stage the competition, including legacy and post-event related activities, the findings of which should be reflected in the human rights strategy;
- A summary report outlining the member association’s stakeholder engagement process (particularly with engagement of human rights stakeholders, including independent external experts, potentially affected groups and other relevant stakeholders) implemented as part of the development of the aforementioned human rights strategy;
- Government declarations and guarantees from the host countries as well as the proposed host cities, stating their full support for FIFA and the member association in their efforts to host and stage the competition in accordance with the UNGPs; and
- Signed stadium, training site, airport and hotel agreements from relevant authorities, whereby they undertake to conduct all competition-related activities in accordance with the UNGPs.
FIFA has made available the submissions of each city selected to act as a Host City for World Cup 2026.
FIFA World Cup 2026 is the first tournament—or global event—to enact a human rights due diligence exercise of this size. With NGOs and other human rights groups over the years claiming that the tournament contributes to increases in human rights abuses in areas selected to host the festivities and in connection with the production of tournament merchandise, the attention will be on World Cup 2026 and surrounding events to determine the efficacy of these new due diligence and operational processes and opportunities for improvement. Host Cities and World Cup 2026 partners will be expected to strictly comply with their commitments as submitted in the bidding process, as well as flowing these commitments through to their contractors and subcontractors. FIFA’s human rights diligence processes requires expertise and compliance throughout a stakeholder’s operations, similar to the application of anti-bribery and corruption diligence. As we assume FIFA World Cup 2026 will be under a microscope, commercial partners, contractors, and subcontractors should be reviewing their existing approaches to these issues to determine if and how they should be improved to ensure, on the front end, that they can compete in bidding processes, and on the back end, decrease risk of greenwashing litigation or reputational damage.