UK Government Commits to Introducing Mandatory Human Rights Due Diligence Regime

Yesterday, in a statement from the Department for Business, Innovation, Science and Trade, the UK government committed to legislate to introduce a mandatory human rights due diligence regime under which the government will introduce powers to be able to remove goods made with forced labour from the market. The announcements follow a government review into responsible business conduct.  

This is a significant step and comes against a backdrop of calls for the UK to strengthen its modern slavery and human rights framework following developments elsewhere, including in the European Union (EU).  

The proposed regime 

What: A mandatory human rights due diligence regime across the UK for services, and in Great Britain for goods. In-scope businesses will be required to identify, assess and address risks of human rights abuses and labour exploitation within their operations and supply chains. The regime will be “risk-based, proportionate and reflect how responsible businesses already manage risk by aligning with established international standards, including the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights”.  

Under the regime, the government will introduce powers to remove goods made with forced labour from the Great Britain market. A regulator will be empowered to investigate businesses suspected of placing such goods on the market and, where due diligence obligations have not been met and forced labour is identified, direct their withdrawal. This will provide “a clear and targeted mechanism for tackling some of the most serious abuses in global supply chains and protecting responsible business from unfair competition”. In Northern Ireland, the government will apply the EU Forced Labour Regulation (FLR) under the Windsor Framework. 

Alongside this, the government will establish a responsible business conduct guidance hub on GOV.UK, to bring together guidance, tools and templates in a single location to support businesses.  

Who: It will apply to UK businesses with a global turnover of over £350 million, as well as non-UK businesses with a UK-generated turnover of over £350 million. The government has stressed that reform must be proportionate and pragmatic – as such, requirements will focus on large businesses “best placed to manage supply chain risks”.  

When: The government will introduce measures to support businesses “as soon as parliamentary time allows”. Whether the wider regime will also be introduced as soon as parliamentary time allows is less clear but this can perhaps be inferred.  

The government’s statement is relatively high level, however, and we await further clarity on a number of points, including what the possible consequences would be for service companies if they are found to be in breach of the regime (such as pecuniary penalties), who the regulator will be, and whether other scoping criteria will be applied beyond the turnover thresholds, for example to specify the types of businesses covered.  

Background and related developments 

On 30 June 2026, the government presented the Immigration and Asylum Bill to Parliament, proposing significant changes to the section 54 Modern Slavery Act 2015 regime, which requires in-scope entities to publish slavery and human trafficking statements. The Bill notably did not include a mandatory human rights due diligence regime (although amendments were proposed at the Committee stage), despite previous recommendations to do so, including from the Joint Committee on Human Rights and the Independent Anti-Slavery Commissioner. In yesterday's statement, the government notes that while plans to strengthen the Modern Slavery Act through the Immigration and Asylum Bill are an “important step”, further action is needed to “bring [the UK] in line with key partners”. This is perhaps particularly relevant in light of developments in the EU, which has introduced two significant pieces of legislation to help tackle human rights impacts and forced labour in companies’ supply chains: the FLR and the Corporate Sustainability Due Diligence Directive (CS3D). 

The CS3D, which will apply from 26 July 2029, requires in-scope companies to conduct risk-based human rights and environmental due diligence to identify actual or potential impacts arising from their own operations, those of their subsidiaries and parts of their chains of activities, and then take appropriate measures to address these, which could include remediation. The FLR aims to ensure that products made with forced labour are not sold into or exported from the EU market. Products found to be made with forced labour will be banned and non-compliant producers can be fined. The substantive provisions become applicable on 14 December 2027.  

As noted above, in Northern Ireland, the government will apply the FLR under the Windsor Framework, noting that both regimes “aim to deliver a similar effect in practice”. The wording in the government's statement may provide insight into how the UK regime will operate. It notes that a future regulator will be able to withdraw goods made from forced labour, where forced labour is identified and due diligence obligations have not been met. Under the FLR, due diligence is not mandatory but due diligence processes, including under the CS3D, may provide useful information during investigations into whether forced labour is present in a product. Conducting due diligence does not provide blanket protection from product bans, but businesses who can demonstrate robust due diligence processes will likely be in an advantageous position.  

Several other jurisdictions have also implemented, or are contemplating, similar measures. For example, in July, the Australian government announced plans to introduce a new criminal offence of “failure to prevent” modern slavery. In June, the Canadian government introduced Bill C-35, which would prohibit imports of goods produced by forced labour, and would complement Canada’s existing Fighting Against Forced Labour and Child Labour in Supply Chains Act, which focuses on transparency and reporting obligations. The US’s Uyghur Forced Labour Prevention Act came into effect in 2022, creating a rebuttable presumption that products from the Uyghur Autonomous Region of China are made with forced labour and are barred from entry. 

The legislative landscape has changed significantly since the introduction of the Modern Slavery Act in 2015. The introduction of a mandatory human rights due diligence regime will help to assuage concerns that the UK has fallen behind other countries in tackling modern slavery, and provides meaningful recognition of the social and economic costs of serious abuses in global supply chains. 

The government’s comments that the regime will protect responsible businesses from unfair competition will be welcome for those companies who already operate due diligence programmes reflecting the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights, or mandatory frameworks in the EU and elsewhere.