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On 4 November 2026, the UK government announced plans to introduce mandatory human rights due diligence for large businesses, alongside new powers to remove goods made with forced labour from the Great Britain market. This is one of the most significant developments in the UK’s approach to modern slavery since the introduction of the Modern Slavery Act 2015.
More than a decade ago, the UK helped establish corporate transparency as a cornerstone of modern slavery compliance. Now, the government is moving toward a framework that would require businesses to identify, assess and address human rights risks across their operations and supply chains, rather than simply report on the steps they have taken.
The announcement reflects a broader shift we have been tracking closely at Ethixbase360, both through our regulatory research and our work supporting organizations with modern slavery and human rights due diligence. Transparency remains important, but the expectations placed on businesses have evolved considerably.
Despite progress in this area globally which has started to accelerate in recent years, it is estimated by the International Labour Organisation (ILO) 27.6 million people are still trapped in forced labour worldwide with around two-thirds of cases linked to global supply chains.
What the UK government has announced
In its Written Ministerial Statement on Responsible Business Conduct, the government acknowledged that the UK’s framework for preventing forced labour is fragmented and relies too heavily on voluntary action and reporting, leaving it out of step with G7 partners and other major trading economies.
The government has committed to introducing a mandatory, risk-based human rights due diligence regime applying to:
- UK businesses with global turnover exceeding £350 million.
- Non-UK businesses generating more than £350 million in UK turnover.
Businesses within scope would be required to identify, assess and address risks of human rights abuses and labour exploitation across their operations and supply chains.
The government also plans to introduce powers allowing a regulator to 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 proposed regime would apply across the UK for services and in Great Britain for goods. In Northern Ireland, the EU Forced Labour Regulation, which applies from December 2027, will apply under the Windsor Framework.
The requirements are intended to align with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. The government has described its approach as phased and proportionate and also plans to establish a responsible business conduct guidance hub on GOV.UK.
The announcement is a commitment to legislate, rather than the introduction of new legal obligations. No bill or confirmed implementation timetable has yet been published.
From disclosure to due diligence: How we got here
When the UK introduced the Modern Slavery Act in 2015, it was widely considered pioneering legislation. Section 54 required qualifying businesses to publish annual statements describing the steps they had taken to address slavery and human trafficking risks in their operations and supply chains.
The legislation helped bring modern slavery onto the agendas of boards, compliance, procurement and risk management teams. But it also had limitations. Businesses were required to disclose their efforts, rather than undertake prescribed due diligence or demonstrate that their measures were effective.
Over the following decade, other jurisdictions moved further. France introduced its Duty of Vigilance Law in 2017, Australia its Modern Slavery Act in 2018, and Germany its Supply Chain Due Diligence Act in 2021. The EU adopted the Corporate Sustainability Due Diligence Directive and the Forced Labour Regulation in 2024. In the United States, enforcement of the Uyghur Forced Labor Prevention Act 2021 since June 2022 has placed greater scrutiny on goods entering the US market.
While these frameworks differ considerably in scope and enforcement, they reflect a growing expectation that businesses take a more active role in identifying and addressing human rights risks.
The UK has also been considering changes to its existing reporting framework. As discussed in our recent webinar with Norton Rose Fulbright, proposed amendments to the UK Modern Slavery Act would introduce more prescriptive reporting requirements, a comply-or-explain approach and potential financial penalties for non-compliance.
The latest announcement goes considerably further. Rather than strengthening what businesses must disclose, the government is proposing requirements governing what businesses must actually do.
A shift we have been tracking at Ethixbase360
This development is consistent with a trend we have been examining throughout 2026.
In August, Ethixbase360 published From Disclosure to Enforcement: Modern Slavery and Human Rights Regulation in 2026, prepared with input from Norton Rose Fulbright. The guide examines developments across 14 jurisdictions, documenting how governments are moving beyond transparency requirements toward mandatory due diligence, import restrictions, financial penalties and other enforcement mechanisms.
One of the central conclusions was that organizations can no longer rely on policies and annual statements alone. They increasingly need to demonstrate that their risk management processes are working, supported by documented decisions and evidence of action.
More recently, our October webinar, From Statement to Proof: What UK and Australian Modern Slavery Reforms Signal for Global Compliance Programs, brought together Norton Rose Fulbright partners Stuart Neely and Abigail McGregor to discuss what these developments mean in practice.
The discussion focused on the importance of understanding supply chains, prioritizing higher-risk relationships and documenting the actions taken when concerns are identified. We also discussed why organizations should not wait for legislation to be finalized before assessing whether their existing programs are sufficiently robust.
The UK’s latest announcement makes that discussion particularly timely.
It also reinforces a point we have emphasized throughout our work at Ethixbase360: identifying potential supply-chain risks is important, but businesses also need the processes and information necessary to address them and build supply-chain resilience.
What businesses should be doing now
The proposed UK regime is not yet law, and many of the details remain to be determined. Nevertheless, businesses do not need to wait for new legislation to assess the effectiveness of their existing programs.
Based on our regulatory research and work with organizations, four areas deserve particular attention:
- Supply chain visibility. Understanding where modern slavery and human rights risks may exist, including beyond direct suppliers. Country and industry indicators are useful starting points, but they should be supplemented with information about individual supplier practices and controls.
- Effective controls. Assessing whether human rights commitments are supported by appropriate measures, including employee and supplier training, grievance mechanisms, supplier oversight and remediation procedures.
- Risk-based prioritization. Directing more intensive due diligence toward the suppliers, activities and products presenting the greatest potential for harm, rather than applying the same level of scrutiny across every relationship.
- Evidence of action. Maintaining clear records of risks identified, decisions made, corrective measures implemented and outcomes monitored. Businesses should be able to explain not only what their policies require, but how those policies are being applied in practice.
For multinational organizations, the challenge is also managing these expectations across different regulatory regimes.
The objective should not be to create a separate compliance program for every new law, but to establish a consistent, adaptable due diligence framework that can accommodate jurisdiction-specific requirements.
Moving from assessments to ongoing due diligence
As regulatory expectations have evolved, so has the way organizations approach modern slavery and human rights risk management.
Supplier questionnaires and initial risk assessments remain important tools for establishing a baseline, understanding supplier practices and identifying areas requiring further attention, but they are not sufficient on their own.
Modern slavery and human rights risks can change as suppliers expand into new markets, alter recruitment practices, engage subcontractors or respond to changing economic and geopolitical conditions. Effective due diligence therefore needs to be an ongoing process, rather than a one-time assessment or reporting exercise.
At Ethixbase360, our approach has evolved to support these broader requirements. Working with the subject matter input from Norton Rose Fulbright’s dedicated international human rights team the Modern Slavery Supply Chain Risk Assessment Questionnaire and Human Rights Supply Chain Due Diligence Questionnaire help organizations identify, manage and report on modern slavery and broader human rights risks in their supply chains and plan programs to respond across multiple jurisdictions.
The goal is not simply to collect more information. It is to help organizations understand where they should focus their attention, respond appropriately when concerns arise and maintain evidence of the actions they have taken.
Importantly, effective due diligence should not automatically mean disengaging from suppliers when risk is identified. In many cases, engagement and remediation may be more effective in addressing underlying issues and improving conditions for workers and ultimately improving outcomes.
The next chapter of corporate accountability
The Modern Slavery Act 2015 helped establish transparency as an expectation of responsible business conduct. The government’s latest announcement signals the next stage in that evolution, with greater emphasis on due diligence, accountability and evidence of action.
At Ethixbase360, our research and work across global supply chains have highlighted both the progress businesses have made and the challenges that remain. The regulatory landscape will continue to evolve, but the underlying expectations are becoming clearer.
Businesses need to understand their risks, have appropriate processes to address them and be able to demonstrate what they have done.
Ultimately, the effectiveness of modern slavery and human rights due diligence should not be measured simply by the number of statements published, suppliers assessed or risks identified. What matters is whether those efforts lead to meaningful action to prevent exploitation, address concerns and improve conditions for workers throughout global supply chains.
Related resources
- UK Government: Written Ministerial Statement on Responsible Business Conduct, 4 November 2026
- From Disclosure to Enforcement: Modern Slavery and Human Rights Regulation in 2026 — Ethixbase360, August 2026
- What UK and Australian Modern Slavery Reforms Signal for Global Compliance Programs — Ethixbase360