This paper analyses the institutionalisation process of human rights due diligence (“HRDD”), from its origins as an international soft law doctrine into national hard law. The paper offers a comparative overview of the implementation process of HRDD in France and the Netherlands, with the aim to understand how and why institutional change took different forms in the two jurisdictions. The analysis applies the theoretical framework of historical institutionalism in order to understand the nuances of institutional change and assess whether this is a tale of frontrunners and free riders.