Acknowledging the challenges faced by members in implementing Indicator 1.3.1, the following Transition Measure is proposed as guidance for certified members to meet the requirement:

Indicator 1.3.1: The Unit of Certification shall identify existing and potential human rights impacts within its operations and its direct suppliers, through the implementation of Human Rights Due Diligence (HRDD). Existing and potential human rights impacts identified through the HRDD shall be addressed through an action plan developed by the UoC. The action plan shall be reviewed at least once every two years. 

Registration of cases:

All Units of Certification who are unable to fully implement this requirement by 1 June 2026 must register their case with the RSPO Certification Unit by registering through the RSPO-administered online registration form (Qualtrics) below, between 1 June 2026 until 31 August 2026: 

This is applicable only to UoCs undergoing Initial Certification, Annual Surveillance Audit, or Recertification after the effective date of the RSPO Principles and Criteria (P&C) 2024, which is 1 June 2026.

Interim Requirement

During the transition period, the UoC shall demonstrate a documented process that includes:

  1. Identifying human rights risks
  • Identify and record key human rights issues that have occurred or could occur in its operations and direct suppliers.
  1. Prioritising human rights risks

Indicate which of these risks are the most important to address, based on available information such as:

  • past incidents
  • grievances or complaints
  • findings from assessments or audits
  • stakeholder feedback

The UoC may use Human Rights Due Diligence (HRDD) tools, including those listed in Annex 4, to support this process.

Scope during transition

During the transition period, the UoC is not required to:

  1. develop or implement an action plan under Indicator 1.3.1; or
  2. demonstrate monitoring of the effectiveness of actions taken.

For the purpose of this transition measure, compliance is limited to showing a documented process for identifying human rights risks and indicating which risks are the most important to address.

CB evaluation:

During the transition period, Certification Bodies (CBs) shall verify that the Unit of Certification (UoC) has identified and documented human rights risks linked to its operations and direct suppliers, and has indicated which risks are considered the most important to address, based on available information such as past incidents, grievances or complaints, findings from assessments or audits, and stakeholder feedback.

Guidance for Certification Bodies (CBs)

Verification

During the transition period, Certification Bodies (CBs) shall verify that the Unit of Certification (UoC) has identified and documented human rights risks linked to its operations and direct suppliers, and has indicated which risks are considered the most important to address, based on available information such as past incidents, grievances or complaints, findings from assessments or audits, and stakeholder feedback.

Non-Conformity

A Non-Conformity shall be raised where the Unit of Certification has not identified and documented human rights risks. An Observation or Opportunity for Improvement (OFI) may be raised where:

  • risks have been identified, but no priority risks are indicated; or
  • the basis for identifying priority risks is unclear or not supported by available information

Validity Period:

This Transition Measure is effective from 1 June 2026 until 31 December 2026, or until the finalised HRDD Guidance is published, whichever is earlier.

Resources:

Transition Measure Update (Indicator 1.3.1)

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