UK Announces Plans for Mandatory Human Rights Due Diligence and Forced Labor Restrictions

On November 4, 2026, the UK Government announced plans to introduce mandatory human rights due diligence requirements, marking a significant shift from the current approach under the Modern Slavery Act 2015, which relies heavily on transparency and reporting requirements. 

The proposed regime would apply to UK businesses with global turnover exceeding £350 million and non-UK businesses generating more than £350 million in UK turnover. Businesses in scope would be required to identify, assess and address risks of human rights abuses and labor exploitation across their operations and supply chains, in alignment with international standards, including the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.

The proposed requirements would cover services across the UK and goods in Great Britain (England, Scotland and Wales). The Government also plans to empower a regulator to order the withdrawal of goods made with forced labor from the Great Britain market where forced labor is identified and businesses have failed to meet their due diligence obligations.

For Northern Ireland, the Government plans to apply the EU Forced Labor Regulation under the Windsor Framework. Notably, the two regimes differ in design: the EU regulation prohibits placing products made with forced labor on the market regardless of the diligence performed, while Great Britain's proposed power to remove products from the market is conditional on both identified forced labor and a failure to meet due diligence obligations. Businesses operating across Great Britain and Northern Ireland should therefore not assume the regimes are interchangeable.

The Government has not yet announced a commencement date but has indicated that it intends to introduce legislation as soon as parliamentary time allows.