The investigation into labour exploitation in the fashion industry continues, but with an unprecedented judicial shift, a real step-change.
On 4 December 2025, the Milan Prosecutor’s Office formally requested that 13 major luxury brands — including Prada, Gucci, Versace, Dolce & Gabbana, Missoni, Ferragamo, Yves Saint Laurent, Givenchy, Pinko, Coccinelle, Adidas Italia and Off-White — provide a large set of internal corporate documentation: organisational charts, supplier contracts, audit reports, traceability documentation, organisational models, codes of ethics, disciplinary systems, and supply-chain controls.
No accusations have been issued. No receivership has been imposed. No precautionary measures have been taken.
Until just a few weeks ago, the approach was entirely different. When investigators identified systematic labour exploitation (clandestine workshops, exhausting shifts, irregular wages, illegal dormitories) they intervened directly and immediately with seizures, arrests and, in the most severe cases, judicial administration imposed on recognised brands.
Not this time. This time, the mechanism is more subtle, more surgical, more strategic.
A message, the strongest ever sent by the judiciary to the sector, and a methodological turning point: no longer repression, but structural analysis.
Authorities are entering the supply chain without pressing charges, but demanding absolute transparency.
It is an invitation to “show your cards” and, at the same time, a warning: if controls are not credible, if suppliers are not traceable, if governance does not properly oversee the supply chain, then the responsibility falls on the brand.
Calling this a “soft phase” is a serious mistake
Reading major newspapers reveals a widespread misconception: this new line taken by Milan prosecutors appears “lighter.”
In reality, it is not lighter at all it is a structured, second-level investigation. It does not deploy the heavy tool of receivership, but it produces an analogous and potentially more disruptive effect.
“Show me that you could not have known. If you cannot prove it, we proceed.”
This is not soft. It is a formal request to prove organisational innocence.
From a hard line to a broader approach
The investigation is no longer “potential.” Authorities are digging deeper to reconstruct the entire opaque production chain, a systemic review of the entire luxury industry in Italy. The formal request for documents means investigators are preparing the ground for potentially more serious measures, with a focus on transparency, governance and compliance.
The phase is document-based, but not merely exploratory: it represents a judicial due diligence on the value chain, conducted with the same criteria applied in the most complex investigations. It is the continuation of a process that began several years ago and had previously resulted in tailored measures for the individual brand involved.
Since then, the issue no longer concerns “isolated cases” but a full production architecture that needs to be rethought. The point is no longer the individual incident because, as now appears clear, this pattern has become recurring.
The sector can no longer treat it as an anomaly. Nor can it avoid being considered responsible for its own supply chain.
What this means for the fashion industry
In a market built on image, quality and reputation, supply-chain transparency is no longer optional: it is a competitive advantage and a compliance requirement.
Today, for a brand, reputational risk is more dangerous than criminal risk. International media publish the news even before prosecutors formally outline a potential offence. Consumers read headlines, not verdicts. Investors react to perceptions, not legal files.
And there is one element brands often underestimate: reputation is not protected through communication, but through control, transparency and technical prevention.
Brands today risk being overwhelmed by a reputational crisis long before a legal one.
Where to begin
For companies operating in the fashion industry, there are two options: wait, or secure themselves. Concrete countermeasures include:
- Implement a truly effective governance and internal control model: a code of ethics is not enough. Clear organisational structures, concrete monitoring activities, and independent, recurring audits are essential.
- Trace and certify the entire supply chain, down to the final subcontractor: transparent contracts, supplier traceability, reporting, surprise inspections, and mapping of first- and second-tier suppliers.
- Conduct 231 stress tests on the supply chain, simulate a real inspection.
- Be ready for total transparency: data, reports, audits, contracts, outcomes. Better to arrive with complete documentation than with “good intentions.”
The core issue at stake
The new investigation does not declare major brands guilty. It states something deeper: the luxury supply chain must change radically because it has become too vulnerable, too fragmented, too opaque to sustain the ethical standard brands publicly claim.
The real test awaiting companies is not the criminal one. It is the test of credibility.
The question every brand should ask today is simple, brutal and unavoidable: “If tomorrow the Prosecutor’s Office knocked on our door, would we be able to prove that our supply chain is under control?”
