The UK Government has taken a significant step towards mandatory supply chain human rights due diligence.

On 4 November 2026, the Secretary of State for Business and Trade, the Rt Hon Jonathan Reynolds MP, announced that the UK will introduce mandatory human rights due diligence requirements for certain businesses. This marks one of the most substantial developments in responsible business regulation since the introduction of the Modern Slavery Act 2015.

However, this is not the only legislative proposal currently under consideration. A number of overlapping initiatives are progressing through Parliament, creating an increasingly complex compliance landscape for businesses operating in the UK.

While key details remain to be clarified, the direction of travel is unmistakable. Companies should now be reviewing and, where necessary, strengthening their human rights due diligence processes, supply chain risk assessments, governance frameworks, policies and public disclosures.

Responsible Business Conduct and Human Rights Due Diligence

Following a review of the UK’s Responsible Business Conduct (RBC) framework, undertaken as part of the Government’s 2025 Trade Strategy commitments, ministers concluded that the UK’s approach to preventing forced labour remains fragmented and overly reliant on voluntary reporting measures. The review also noted that international regulatory developments are advancing more rapidly than the UK’s existing framework.

Pressure for reform has also come from Parliament. In 2025, the Joint Committee on Human Rights recommended the introduction of mandatory human rights due diligence legislation broadly aligned with the EU Corporate Sustainability Due Diligence Directive (CSDDD).

Against this backdrop, the Department for Business and Trade published a Written Ministerial Statement on 4 November 2026 announcing its intention to introduce a mandatory human rights due diligence regime.

Although draft legislation has not yet been published, the Government has indicated that the new framework will:

  • Apply across the UK for services and across Great Britain for goods.
  • Apply to UK businesses with global turnover exceeding £350 million, as well as non-UK businesses generating more than £350 million of turnover within the UK.
  • Introduce powers to remove goods produced using forced labour from the Great Britain market.
  • Establish a regulator with powers to investigate businesses suspected of placing such goods on the market and, where due diligence obligations have not been met, require the withdrawal of products.
  • Create a centralised Responsible Business Conduct hub on GOV.UK, providing guidance, tools and due diligence templates.
  • Introduce sanctions for non-compliance, although details of the enforcement regime have not yet been announced.

The proposed regime appears to be closely aligned with internationally recognised standards, particularly the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights. As with other emerging due diligence regimes globally, the emphasis is expected to be on a risk-based approach that identifies, prevents, mitigates and accounts for adverse human rights impacts throughout business operations and supply chains.

A Potential Great Britain and Northern Ireland Divergence

The announcement also raises interesting questions under the Windsor Framework.

The EU Forced Labour Regulation (EUFLR), which will apply in Northern Ireland, prohibits products made with forced labour from being placed on or exported from the EU market. However, unlike the proposed UK regime, the EUFLR does not itself impose mandatory human rights due diligence obligations. Instead, businesses must look to other EU legislation, including the Corporate Sustainability Due Diligence Directive (CSDDD), the Batteries Regulation and the Conflict Minerals Regulation, for specific due diligence requirements.

If implemented as proposed, the UK regime could therefore create a notable regulatory divergence between Great Britain and Northern Ireland, potentially requiring businesses to navigate different due diligence expectations depending on where products are placed on the market.

Modern Slavery Statements: Enhanced Reporting and Enforcement

Alongside the proposed due diligence regime, the Government is also pursuing reforms through the Immigration and Asylum Bill 2026.

The Bill would strengthen section 54 of the Modern Slavery Act 2015 by requiring in-scope organisations to report on the due diligence processes they have implemented to identify and address risks of slavery and human trafficking within their operations and supply chains, or explain why no such processes have been adopted.

This is a significant shift. Under the existing Modern Slavery Act, organisations are required to publish an annual statement, but there is no legal requirement to undertake due diligence and there are effectively no financial penalties for failing to comply.

The Bill would change that position substantially. Proposed sanctions include financial penalties of up to the greater of:

  • £1 million; or
  • 1% of the organisation’s total turnover.

The legislation remains subject to parliamentary scrutiny, but it demonstrates the Government’s willingness to move beyond transparency-based obligations towards more substantive compliance requirements.

The Commercial Organisations and Public Authorities Duty (Human Rights and Environment) Bill

Further change may come through the Commercial Organisations and Public Authorities Duty (Human Rights and Environment) Bill, a Private Member’s Bill currently progressing through the House of Lords.

This proposal goes significantly further than the Government’s announced due diligence regime. In addition to human rights due diligence, it would introduce environmental due diligence obligations and require organisations to disclose their policies, risk assessments and supply chain due diligence processes.

The Bill would also establish an independent enforcement body with powers to:

  • Issue guidance.
  • Conduct market investigations.
  • Investigate breaches.
  • Take enforcement action.

Notably, the Bill contains some of the strongest enforcement provisions currently under consideration in the UK. These include:

  • Corporate fines of up to 10% of global turnover.
  • Potential director liability.
  • Criminal sanctions, including imprisonment for up to two years in certain circumstances, such as repeated enforcement failures or the provision of false or misleading information in due diligence disclosures.

While Private Member’s Bills face significant hurdles before becoming law, the proposals provide a strong indication of the policy direction being advocated by some parliamentarians and civil society groups.

What Should Businesses Be Doing Now?

Although the precise scope and implementation timelines remain uncertain, businesses should not wait for legislation to be enacted before taking action.

Organisations that are already aligned with the OECD Guidelines and the UN Guiding Principles will be significantly better placed to comply with any future UK due diligence requirements. Practical steps include:

  • Mapping supply chains and identifying areas of heightened human rights risk
  • Conducting and documenting risk-based human rights due diligence
  • Reviewing supplier onboarding, contractual controls and audit programmes
  • Establishing remediation and grievance mechanisms
  • Strengthening governance, oversight and board reporting processes
  • Reviewing public disclosures, including Modern Slavery Statements and sustainability reporting.

For many businesses, the challenge will not be developing entirely new processes, but demonstrating that existing processes are sufficiently robust, documented and effective.

Next steps for business

The UK is moving towards a more interventionist approach to supply chain governance and corporate accountability. Whether through mandatory human rights due diligence, strengthened modern slavery reporting obligations, or broader human rights and environmental due diligence proposals, the regulatory trend is clear.

Importantly, these developments are not creating entirely new expectations. Rather, they are increasingly transforming internationally recognised standards, particularly the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights, into legally enforceable obligations.

The key question for businesses is therefore shifting from whether human rights due diligence should be undertaken to whether your existing due diligence processes can withstand regulatory scrutiny.

For organisations that have not yet embedded human rights due diligence into their governance and supply chain management frameworks, the time to prepare is now.

How we can help

We advise organisations on the legal, governance and operational challenges associated with human rights and supply chain due diligence across global value chains. Our work includes helping businesses respond to evolving requirements relating to modern slavery, forced labour, responsible sourcing and broader ESG-related supply chain risks.

Recent experience includes:

  • Advising multinational organisations on supply chain transparency, modern slavery and human rights due diligence obligations, including the development of governance frameworks, risk assessment methodologies, supplier engagement programmes and disclosure processes.
  • Supporting businesses in assessing and strengthening due diligence procedures relating to forced labour risks, supply chain monitoring, supplier oversight and responsible sourcing programmes in light of evolving UK, EU and international requirements.
  • Assisting organisations with the design and implementation of supply chain compliance and due diligence programmes, drawing on the firm’s experience in international trade compliance, supply chain risk management and cross-border investigations.