The Modern Slavery Amendment (Australian Anti-Slavery Commissioner) Act 2024, which took effect in November 2024, established Australia's first Anti-Slavery Commissioner. In January 2026, the Commissioner published formal recommendations urging Australia to move beyond its current reporting-only model — including a mandatory, risk-based due diligence obligation, a mechanism to designate high-risk products and industries, expanded reporting requirements, and stronger enforcement powers.

On 16 July 2026, Attorney-General the Honourable Michelle Rowland announced that the Commonwealth Government intends to introduce a new criminal offence for companies with annual consolidated revenue over A$100 million that fail to prevent modern slavery in their supply chains. A defence would be available where a company can demonstrate it took reasonable steps to prevent modern slavery — mirroring the foreign bribery offence's "adequate procedures" model.

This section was prepared with input from Norton Rose Fulbright.

The first reporting cycle concluded in 2024. In 2026, Public Safety Canada made it clear that organisations are expected to do more than describe policies — they must demonstrate measurable progress and show how they actively identify, manage, and reduce risks.

On 12 June 2026, the Canadian government tabled Bill C-35 — replacing the current Customs Tariff prohibition with a standalone legislative framework giving the Minister of Foreign Affairs authority to designate high-risk goods by producer, country, or region where there are reasonable grounds to suspect forced labour.

This section was prepared with input from Norton Rose Fulbright.

For multinational companies, this creates a direct regulatory collision whereby compliance with the UFLPA, CSDDD, or LkSG may trigger non-compliance with Chinese law. Managing this tension will require companies to take an integrated, multi-jurisdictional approach to supply chain risk, one that accounts for conflicting legal obligations simultaneously.

This section was prepared with input from Norton Rose Fulbright Shanghai Pacific Legal.

The EU remains the global leader in mandatory due diligence. The CSDDD requires large companies to identify, prevent, and mitigate human rights and environmental risks throughout their operations and value chains. The EU Forced Labour Regulation bans the sale, importation, or exportation of products made with forced labour, giving authorities the power to investigate, withhold, and remove products from the EU market.

EU Member States will be required to transpose the CSDDD into national law by July 2028, moving the EU from disclosure-based obligations towards enforceable due diligence backed by trade restrictions, product bans, and greater scrutiny of supply chain practices.

This section was prepared with input from Norton Rose Fulbright.

In March 2026, a French court awarded damages in the first successful civil liability case under the Duty of Vigilance Law, caused by alleged labor-rights abuses and anti-union dismissals at the Turkish subsidiary of the Yves Rocher group. The court found that the French parent company failed to identify and address clear risks to trade union rights within its overseas subsidiary, highlighting the regulation's extraterritorial reach.

Although the damages awarded were relatively small, the decision establishes an important precedent: French companies now face civil liability where deficiencies in their vigilance plans contribute to harm in overseas operations or supply chains.

Germany's LkSG requires companies with more than 1,000 employees to establish a formal due diligence framework to identify, prevent and address human rights and environmental risks across their operations and supply chains. BAFA published further guidance in January 2026.

Germany is now entering a transition period as it prepares to align the LkSG with the EU's CSDDD. Core due diligence obligations would remain in force until the CSDDD is implemented into German law.

The Netherlands has not yet finalised a standalone due diligence law, but Dutch authorities have indicated that they expect Dutch companies operating abroad to engage in responsible business conduct by conducting due diligence to identify risks for people and the environment within their own business operations and international value chain.

Modern slavery returned to New Zealand's agenda in February 2026 with the bipartisan Modern Slavery Bill, which has since passed its first reading in Parliament. It is now before the Education and Workforce Select Committee, which is due to report back by 31 August 2026.

This section was prepared with input from Norton Rose Fulbright.

Norway's Transparency Act remains one of the clearest examples to date of a due diligence law backed by meaningful enforcement powers. In late 2025, the Norwegian Consumer Authority issued revised guidance emphasising meaningful stakeholder engagement, ongoing risk-based assessment and prioritisation of risks, stronger follow-up measures, and recognition that a company's connection to adverse impacts is dynamic and may change over time.

The guidance makes clear that due diligence cannot be outsourced entirely to suppliers, auditors, or industry initiatives. Companies remain responsible for identifying and handling risks in their own operations and supply chains.

South Korea is emerging as an important jurisdiction in the field of business and human rights. In 2025, lawmakers reintroduced a Corporate Human Rights and Environmental Due Diligence Bill that would require large companies to identify, prevent and address human rights and environmental risks throughout their operations and supply chains. Enactment remains subject to political negotiation and business opposition; the bill is unlikely to take full effect before 2027 at the earliest.

In April 2026, the Swiss government proposed the adoption of a new Federal Act on Sustainable Corporate Governance, to align with CSRD and CS3D. The legislation would require in-scope companies to report on and undertake risk-based human rights and environmental due diligence, with obligations broadly mirroring those of CS3D including risk assessment and prioritisation, remediation, establishing grievance mechanisms and monitoring. It also provides for civil liability and supervisory oversight for non-compliance.

Thailand's Ministry of Justice is developing a Draft Act on the Promotion of Responsible Business Conduct — the HREDD Bill — first circulated for consultation in July 2025. The draft would impose mandatory due diligence obligations on large enterprises operating in Thailand, including foreign companies that meet the applicable revenue thresholds. The bill has not yet entered the formal legislative process, but it sends a clear signal — reinforced by Thailand's inclusion in the US Section 301 investigation and its OECD accession ambition — that mandatory supply chain due diligence is moving from aspiration to expectation.

On 30 June 2026, the UK government introduced proposed amendments to Section 54 of the Modern Slavery Act 2015, tabled as Part 5 of the Immigration and Asylum Bill, which had its second reading on July 13. The amendments would make the content of modern slavery statements mandatory for the first time — requiring reporting against a prescribed set of topics including risk assessments, policies, due diligence processes, training, and effectiveness measures — and to include a signed accuracy declaration. The bill also introduces financial penalties for non-compliance, a first for the UK's modern slavery reporting regime.

The reforms strengthen transparency and reporting but stop short of mandating human rights due diligence itself and do not introduce a forced labour import ban. A Government minister has separately indicated the government expects to introduce substantive due diligence legislation, along with an EU-style import ban, before the end of this parliament.

This section was prepared with input from Norton Rose Fulbright.

Under the UFLPA, CBP operates a rebuttable presumption that goods sourced from Xinjiang or from entities on the UFLPA Entity List are treated as products of forced labour unless importers can prove otherwise. Since the UFLPA came into effect in 2022, authorities have reviewed more than 10,000 shipments worth over USD 4 billion, and enforcement has expanded to include automotive parts and electronics.

The Office of the USTR launched Section 301 investigations in March 2026 into about 60 countries and trading blocs. On 2 June 2026, the USTR concluded that Canada and roughly 60 other countries were not effectively enforcing forced labour import prohibitions, and proposed a 10% tariff on affected goods.