Launch of ICAR’s “Shadow” U.S. National Baseline Assessment – Pillar III

ICAR is pleased to release the Pillar III section of its "Shadow" National Baseline Assessment (NBA) of U.S. implementation of business and human rights frameworks, including the UN Guiding Principles on Business and Human Rights.

Alongside the release of this section of the Shadow NBA, we have also developed a set of 110 recommendations, organized by government entity, for the U.S. government to consider in shaping the content of the U.S. National Action Plan (NAP) on Responsible Business Conduct. These recommendations directly draw from the protection and enforcement gaps identified in Pillar III of the Shadow NBA.

Pillar III of the Shadow NBA, on access to remedy, is available here. A separate document with the Pillar III Recommendations only is available here.

Pillar I of the Shadow NBA, on the State duty to protect, was released in March and is available here.

Together, these documents represent one of the most exhaustive studies of the various U.S. laws, policies, regulations, and standards that pertain to business and human rights at the national level.

We urge the U.S. government, business groups, investors, and civil society to engage with these tools, add to them, and keep the pressure up to ensure that commitments coming out of the U.S. NAP process are specific, measurable, targeted, and result in follow-up actions.

Please note that a complete report with the full Shadow NBA will be released at the end of July. The complete report will include updates and revisions based on feedback received following the publication of each section.

For more information, visit ICAR's online U.S. NAP portal at or contact Sara Blackwell, ICAR's Legal and Policy Associate, at