Executive Summary
- What’s new: On 4 November 2026, the UK government announced that it intends to legislate to introduce a mandatory human rights due diligence regime, with powers to remove goods made with forced labour from the market.
- Why it matters: The regime will apply to large UK businesses with a global turnover of over £350 million and non-UK businesses with a UK-generated turnover of over £350 million.
- What to do next: Potentially in-scope organisations should consider starting preparations now, including reviewing modern slavery policies and procedures, assessing supply chain risks and reviewing contracts with suppliers.
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On 4 November 2026, the UK government announced that it intends to legislate to introduce a mandatory human rights due diligence regime. As part of this regime, the government will have the power to remove goods made with forced labour from the UK market, while a regulator will be empowered to investigate businesses suspected of placing such goods on the market.
These proposals complement the reforms to the Modern Slavery Act 2015 (MSA) proposed earlier this year as part of the Immigration and Asylum Bill and will require large companies within scope of the new regime to address risks of human rights abuses and labour exploitation within their operations and supply chains.
Criticisms of the Modern Slavery Act and Proposed Reforms
As we noted in our 22 July 2026 client alert, “Proposed Amendments to the UK Modern Slavery Act: New Financial Penalties and Enhanced Reporting Obligations,” many commentators deem the UK’s current supply chain transparency requirements under the MSA to be insufficient. While the MSA imposes a duty on certain in-scope companies to prepare a modern slavery statement for each financial year,1 organisations retain discretion as to what their statement contains, and there are currently no statutory financial penalties that can be imposed directly on organisations for noncompliance.
In our previous client alert, we explored the amendments to the MSA proposed by the UK government in June 2026 as part of the Immigration and Asylum Bill. These amendments include the introduction of a civil penalty regime for noncompliance with the obligation to publish a modern slavery statement and mandatory disclosure requirements regarding the content of such statements.
More generally, the adequacy of the UK’s current framework has long been the subject of criticism. In 2025, an independent government-commissioned review called for a more substantive human rights due diligence framework, while the government’s July 2025 UK Trade Strategy announced a review into the government’s approach to responsible business conduct.
Mandatory Human Rights Due Diligence Regime
On 4 November 2026, the UK government announced the outcome of its responsible business conduct review. Overall, the review found the UK’s current framework for preventing forced labour to be “fragmented and overly reliant on voluntary action and reporting measures.” The statement added that, while plans to strengthen the MSA through the proposed reforms in the Immigration and Asylum Bill are important, “further action is needed to bring [the UK] in line with key partners.”
In light of these conclusions, the UK government has announced that it intends to legislate to introduce a mandatory human rights due diligence regime for goods and services. The government intends the regime to apply only to large businesses with the capability to manage these risks within their supply chains, as follows:
- UK businesses with a global turnover of over £350 million.
- Non-UK businesses with a UK-generated turnover of over £350 million.
By comparison, the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) has a much higher threshold for applicability. The CSDDD will generally apply to in-scope companies from 26 July 2029 and require such companies to conduct due diligence across their entire “chains of activities” globally to ensure compliance with human rights and sustainability standards. The directive applies to:
- EU companies with more than 5,000 employees and a global net turnover exceeding €1.5 billion.
- Non-EU companies generating more than €1.5 billion in turnover within the EU.2
Companies within scope of the new UK regime will be required to identify, assess and address risks of human rights abuses and labour exploitation within their operations and supply chains.
As part of the new regime, the government will also introduce powers that will allow the removal of goods made with forced labour from the Great Britain market.3 A regulator, yet to be designated, will be empowered to investigate businesses suspected of placing such goods on the market and, where due diligence obligations have not been met and forced labour is identified, direct withdrawal of those goods.
Next Steps for In-Scope Organisations
While there is no timeline for introducing legislation to implement the regime, tackling modern slavery and forced labour is a key focus of the government. As such, in-scope organisations should consider starting preparations now, particularly as the Immigration and Asylum Bill — which aims to enhance the requirements imposed by the MSA — continues to make its way through Parliament.
Potentially in-scope organisations should consider the following steps:
- Review and strengthen modern slavery policies and procedures. Consider whether the new human rights due diligence regime will require the introduction of enhanced policies, procedures and controls to identify, prevent, mitigate and remediate human rights abuses in the organisation’s operations and supply chains.
- Conduct a risk assessment of the organisation’s supply chains. Consider mapping the organisation’s supply chains and assessing which suppliers and jurisdictions pose the highest risk. This work should be considered in tandem with any risk assessments being conducted in relation to the EU CSDDD and the EU Forced Labour Regulation (to the extent those regimes also apply to the organisation).
- Assess contracts with suppliers. Review standard terms with suppliers for forced labour and modern slavery warranties, and for audit and information rights. Consider whether to enhance these terms to allow for the identification and prevention of human rights abuses.
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1 This requirement is set out in section 54 of the MSA and applies to companies in any sector that (i) supply goods or services, (ii) carry on a business or part of a business in the UK, and (iii) have a total turnover of at least £36 million. For further background on the MSA, see our 19 September 2024 client alert, “UK Modern Slavery Act: The Future of Transparency in Supply Chains.”
2 When it first came into force in July 2024, the threshold for applicability of the EU CSDDD was much lower (i.e., EU companies with more than 1,000 employees and net worldwide turnover of more than €450 million, and non-EU companies with net worldwide turnover of more than €450 million in the EU). However, the European Parliament increased this threshold as part of its agreement to adopt proposed changes to the CSDDD in December 2025. For further detail on the amendments to the EU CSDDD, see our 12 January 2026 client alert, “2025 ESG Wrap-Up and 2026 Outlook.”
3 Under the Windsor Framework (a post-Brexit agreement signed in February 2023 between the UK and EU that introduced simplified processes for moving goods from Great Britain to Northern Ireland), the UK will apply the EU’s Forced Labour Regulation in Northern Ireland. The EU’s regime, which will apply from December 2027, is also designed to ensure goods made with forced labour can be withdrawn from the market.
This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.