From NAP to Nowhere: Why Strategic Design Matters for Business and Human Rights NAP Implementation

Korean businesses face mounting pressure from EU human rights regulations, particularly the Corporate Sustainability Due Diligence Directive affecting over 18,000 firms. Yet Korea's National Action Plan on Business and Human Rights, integrated within broader human rights plans since 2018, functions primarily as symbolic compliance rather than strategic governance. This article employs experimentalist governance theory, policy coherence analysis, and UN Working Group standards to examine why Korea's NAP has failed to catalyze institutional reform despite early adoption. The analysis reveals systematic governance failures across four interconnected dimensions: institutional fragmentation rooted in developmental state legacies, political economy resistance prioritizing economic competitiveness, civil society engagement deficits excluding meaningful stakeholder participation, and corporate compliance cultures resistant to human rights integration. These barriers systematically prevent the participatory problem-solving, iterative learning, and adaptive coordination that characterize strategic NAP implementation. Comparative case studies of Germany's evidence-based escalation strategy, the Netherlands' stakeholder co-governance model, and Thailand's coordination mechanisms demonstrate how strategic NAP design addresses comparable governance challenges through institutional innovation. Germany's conditional escalation framework shows how monitoring evidence supports policy development from voluntary to mandatory measures. The Netherlands' IRBC covenants illustrate how formal stakeholder partnerships distribute implementation responsibility. Thailand's institutional architecture demonstrates systematic coordination mechanisms enabling effective multi-stakeholder engagement. Korea's approach reflects broader patterns among democratic developmental states where path-dependent constraints prevent institutional transformation required for effective business and human rights governance. The analysis contributes theoretical insights about how domestic institutional architectures shape international norm implementation while providing practical guidance for transforming symbolic compliance into strategic governance capacity.