In a written ministerial statement on 4 November 2026, the UK Government announced its intention to legislate for a mandatory human rights due diligence (mHRDD) regime. The proposed regime will include powers to require goods made with forced labour to be withdrawn from the Great Britain market where due diligence obligations have not been met. This marks a significant change in the UK’s approach, following previous government reluctance to support comparable legislative proposals.
This announcement follows sustained criticism that the UK has fallen behind comparable jurisdictions. The Government’s review of responsible business conduct, undertaken as part of its Trade Strategy commitments, concluded that the existing UK framework is fragmented and overly reliant on voluntary action and reporting. The proposals would move the UK beyond the transparency-focused model under the Modern Slavery Act 2015 (MSA). Separate reforms proposed in the Immigration and Asylum Bill would strengthen MSA reporting requirements, including mandatory content and director-level verification for organisations meeting the existing GBP36 million turnover threshold, but the Government has concluded that such reporting reform alone is insufficient.
The mHRDD regime is expected to apply directly only to the largest businesses. It is expected to cover UK businesses with a global turnover of more than GBP350 million and non-UK businesses generating more than GBP350 million in UK turnover. However, its practical impact is likely to extend throughout their supply chains. In-scope businesses will be required to identify, assess and address risks of human rights abuses and labour exploitation in their operations and supply chains, and are therefore likely to seek stronger information, assurances and contractual commitments from their own suppliers.
No Bill, draft legislation or detailed implementation timetable has yet been published. The UK Government has said that legislation will be introduced “as soon as parliamentary time allows”, with the measures expected to apply no earlier than December 2027. The detail remains to be developed, but the direction of travel is clear.
What do we know so far? A regulator will be empowered to investigate businesses suspected of placing goods made with forced labour on the Great Britain market and, where due diligence obligations have not been met and forced labour is identified, direct the withdrawal of those goods. The approach has clear parallels with the EU Forced Labour Regulation, which will apply from 14 December 2027. Subject to the relevant Windsor Framework process, the EU Regulation is also expected to apply in Northern Ireland, while the proposed UK market-withdrawal powers would apply in Great Britain.
The due diligence requirements are expected to align with established international standards, including the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.
The Government has emphasised that the new regime will be risk-based, proportionate and pragmatic. This is intended to focus compliance activity on the most significant risks rather than impose a uniform process on every business. Even so, the shift is material. For businesses within scope, voluntary alignment with international standards would be replaced by legal duties, regulatory scrutiny and the potential withdrawal of affected goods from the market..
Businesses that may be directly or indirectly affected should begin preparing now. Priority steps include mapping higher-risk supply chains beyond tier one; conducting a gap analysis against the OECD Guidelines and UN Guiding Principles; strengthening supplier due diligence, contractual protections and procurement controls; clarifying governance, accountability and escalation routes; establishing remediation and product-withdrawal controls; and aligning compliance programmes across relevant UK, EU and other international regimes.
