As scrutiny of Italy’s luxury supply chains intensifies, the question of who should pay for greater oversight is coming into focus. In July, Italian police requested governance and supply chain records from nine luxury companies, including Chanel, Goyard, Moncler and Brunello Cucinelli, amid concerns about labor exploitation at subcontracting factories, following similar requests involving 13 companies in December 2025. At the time, Reuters reported that none of the nine companies was under investigation or subject to a request for judicial administration.
The July scrutiny extended to packaging, such as garment bags and pouches, illustrating how far a luxury brand’s production network – and the corresponding compliance burden – can reach.
Against that background, the question for the industry is how to make oversight effective across sprawling production networks, including at workshops with limited administrative resources. More checks require staff time, reliable information, and money. How much of that work can brands sensibly share?
The Cost Beyond the Audit
Italy’s production structure matters. Unioncamere described a fashion and accessories sector of more than 50,000 companies and 500,000 workers in May 2026. Within that ecosystem, small specialist businesses contribute the technical skills needed to turn global brands’ designs into finished products.
For a workshop serving several brands, separate questionnaires and inspections can mean repeated requests for similar records. The OECD warns that duplicate supplier assessments can impose unnecessary burdens without improving information or suppliers’ capacity. The cost of a control system includes more than the auditor’s invoice. Someone must maintain records, answer questions, and investigate discrepancies.
There is also a difference between paying to demonstrate compliance and paying to improve conditions. A shared questionnaire may reduce duplication. It will not fund safer equipment, correct unpaid wages, or make an unrealistic delivery schedule workable. Limited resources cannot excuse unlawful conditions, but multiplying paperwork alone will not correct them.
What the Industry is Already Building
Efforts to coordinate are already underway. In May 2026, Camera Nazionale della Moda Italiana and the Fédération de la Haute Couture et de la Mode announced a shared ESG framework. It offers voluntary business conduct principles, supporting documents, and training across governance, workplace safety, labor and human rights, and environmental matters. Its stated purpose includes reducing fragmentation for suppliers. Each operator still determines its own due diligence approach.
The Milan fashion protocol signed in May 2025 provides another route, establishing a framework for a shared digital platform to collect supplier documentation and generate a Green List of participating suppliers that meet specified transparency and compliance criteria. Participation remains voluntary, however, raising questions about the initiative’s ability to address labor abuses throughout Italy’s luxury supply chains.
The practical test is whether shared information helps a buyer understand current production. An assessment should identify the sites covered, when they were inspected, and what remains unresolved. Buyers also need to know whether production has moved or another subcontractor is involved. Common forms are useful only if the information behind them is accurate and updated.
Who Should Pay?
A workable model could start by having the brands that use the information help pay for collecting and maintaining it. Instead of each buyer commissioning substantially overlapping checks, participating brands could fund a common assessment and documentation service. A buyer requesting additional checks for its own purposes could pay for those separately. Such a service would need safeguards for independent assessments, controlled access to commercially sensitive information, and a clear process for challenging inaccurate findings. Suppliers should be able to correct or update a record without repeating the exercise for every customer. Brands would still need to review whether the shared findings cover their own orders and respond to warning signs.
Italy’s €100 million incentive scheme for fashion SMEs is not a dedicated compliance subsidy, but it supports development programs that can include organizational innovation and training. The ministerial decree also connects selection to responsible business practices, with ranking criteria that include ethical and social certifications and supply chain traceability.
More targeted support could help workshops establish payroll systems, maintain production records, and train staff. Trade associations could organize shared administrative assistance. Investment in actual workplace improvements would still need an identified budget and responsibility for delivery. The relevant question is how much spending reaches those improvements after the cost of documenting them has been paid.
What Remains with the Brands
Cooperation has limits. The OECD’s garment and footwear guidance supports collaboration while preserving each enterprise’s responsibility for its own due diligence. A common assessment can inform a purchasing decision, but it cannot establish that every subsequent order will be produced at the same site or under the same conditions.
That makes purchasing teams part of the compliance system. The OECD’s 2026 overview identifies production planning, short lead times, and buyer practices as factors that can increase reliance on overtime. Before placing an order, a brand should ask whether the supplier has the capacity to complete it lawfully at the agreed price and deadline. A positive assessment loses much of its value if the buyer then demands volumes the assessed workshop cannot produce.
Italy’s reputation for craftsmanship gives brands a commercial reason to invest in the businesses behind it. The opportunity is to direct more of that investment toward reliable information and lawful production, while reducing avoidable duplication.
This article draws on research undertaken for the author’s thesis, Made Lawfully in Italy, forthcoming in the Marquette Intellectual Property & Innovation Law Review in December 2026.
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