UK Plans to Make Human Rights Due Diligence Mandatory, Here Is What We Know So Far

On 4 November 2026, the UK government published a written statement on the outcome of its responsible business conduct review. The headline is that the UK intends to require large businesses to carry out human rights due diligence across their operations and supply chains. For compliance teams who have spent the last decade working with the Modern Slavery Act, this is the most significant shift in UK supply chain regulation since 2015.

Detailed proposals have not been published yet, so much of the picture is still forming. This article summarises what the government has announced, how it fits alongside existing rules, and the questions that remain open.

The UK is moving beyond a disclosure-based model

The Modern Slavery Act 2015 requires organisations with annual turnover of £36 million or more to publish a yearly statement on the steps they have taken to address modern slavery. Section 54 of the Act requires a transparency statement but imposes no due diligence obligations.

The review found the UK’s current framework for preventing forced labour to be “fragmented and overly reliant on voluntary action,” and the government acknowledged that the UK has fallen out of step with G7 partners and other major trading economies. The review followed the UK’s June 2025 Trade Strategy, and the Independent Anti-Slavery Commissioner had already published model legislative drafting on human rights due diligence in December 2025. Developments in the EU, particularly the Corporate Sustainability Due Diligence Directive (CSDDD), also raised expectations that the UK would act.

The government has made three core commitments

• The first is mandatory human rights due diligence, requiring in-scope businesses to identify, assess, and address risks of human rights abuses and labour exploitation in their own operations and supply chains.

• The second is a market-withdrawal power, under which a regulator can investigate businesses suspected of placing goods made with forced labour on the Great Britain market and direct their withdrawal where forced labour is identified and due diligence obligations have not been met.

• The third is a centralised guidance hub on GOV.UK that brings together guidance, tools, and templates.

The government has said the regime will be risk-based and proportionate, and aligned with the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights. Many larger organisations already reference these frameworks in their human rights policies, which may make the direction of travel familiar even if the legal obligations are new.

The law is expected to apply to the largest businesses

The due diligence law will apply to UK businesses with global turnover above £350 million and to non-UK businesses with UK-generated turnover above £350 million. That threshold is nearly ten times the Modern Slavery Act’s £36 million reporting threshold, which signals a focus on companies with the capability and leverage to manage supply chain risk.

The geography is also worth noting. The law will apply across the whole UK for services but only in Great Britain for goods, because Northern Ireland will apply the EU Forced Labour Regulation under the Windsor Framework. The government set out more detail in a separate policy paper on the Forced Labour Regulation in Northern Ireland.

Companies below the threshold may still see effects, while larger in-scope businesses seek contract provisions from suppliers, such as information and audit rights, and notes that it is not yet clear whether the UK will limit this “trickle down” of obligations in the way the EU did with CSDDD.

The announcement sits within a wider set of regulations

Many multinational organisations already work across several overlapping regimes, and this announcement adds another. Businesses that fall within scope of both the UK law and CSDDD will have to comply with both, and the simplified CSDDD applies at materially higher thresholds, generally over 5,000 employees and €1.5 billion in turnover. The UK statement does not suggest environmental impacts will be a specific focus, unlike CSDDD, although human rights and environmental risks often overlap in practice.

Timing also links the UK and EU approaches. An accompanying written statement says the government aims for the measures to take effect in December 2027, to coincide with application of the EU Forced Labour Regulation in the EU and Northern Ireland. Covington observes that combining a due diligence model with a market-withdrawal mechanism suggests the UK may be trying to bring some coherence between due diligence regimes and forced labour import bans. For organisations that also trade with the US, the Uyghur Forced Labor Prevention Act remains part of the same picture.

Separate reforms to the Modern Slavery Act are already in Parliament

The due diligence law is distinct from changes already underway to the Modern Slavery Act. On 30 June 2026, the government introduced reforms to the Act’s reporting regime through the Immigration and Asylum Bill, including mandatory disclosure categories and updated approval requirements. These changes would require more detailed due diligence disclosures in modern slavery statements, strengthen board and director sign-off, and introduce fines of up to 1% of turnover for failing to publish a statement. It’s expected that these reforms will be adopted regardless of the due diligence legislation.

In practice, this means UK obligations may change on two tracks. Reporting requirements under the Modern Slavery Act are likely to become more demanding for organisations above £36 million, while the largest organisations will also face a new duty to act on the risks they identify.

Several important details have not yet been decided

The announcement leaves a number of questions open, and these are the areas most commentators are watching.

• Timing: The statement does not set out a legislative timetable, and the government has said it will introduce the measures as soon as parliamentary time allows. The December 2027 target is an aim rather than a confirmed commencement date.

• The regulator: The identity of the regulator or regulators has not been confirmed.

• Liability: It is unclear whether there will be civil or criminal liability for violations. The Independent Anti-Slavery Commissioner’s model drafting included civil liability provisions, and it remains to be seen whether the government adopts this or leaves the question to the courts.

• Supplier protections: Whether the UK will include measures to limit obligations passed down to smaller suppliers has not been addressed.

• Detailed requirements: The specific steps businesses will be expected to take, and what the guidance hub will contain, will depend on proposals that have not yet been published.

The government has said it will work closely with stakeholders on design and implementation, so there are likely to be opportunities for public consultation.

Scrutiny of business conduct is already increasing

Even before legislation is drafted, attention on this area is growing. According to a Financial Times report, the UK’s Office for Responsible Business Conduct (the national contact point for complaints under the OECD Guidelines) registered a sevenfold rise in complaints over five years. Law firm commentary suggests organisations are monitoring legislative progress, considering whether any entities are likely to meet the £350 million threshold, and looking at how the new rules will align with the Modern Slavery Act, CSDDD, and the EU Forced Labour Regulation.

The direction is clear even though the details are not

The UK has signalled a decisive move from asking companies to report on modern slavery toward requiring them to identify and address human rights risks, backed by a regulator with the power to remove goods from the market. For organisations operating across the UK, the EU, and the US, the announcement adds to a growing body of regulation that shares common foundations in international standards.

To learn more about how GAN Integrity helps some of the world’s largest enterprises build best-in-class compliance programmes, contact us here.

This article does not constitute legal advice, and organisations should consult qualified legal counsel on how these developments apply to them.