Beyond modern slavery reporting: The UK’s proposed move to mandatory human rights due diligence
GoodBlog | read time: 6 min
Published: 11 November 2026
The UK Government’s announcement on 4 November 2026 that it intends to introduce mandatory human rights due diligence (mHRDD) marks an important shift in its approach to business and human rights. It signals a move away from relying on corporate reporting towards requiring large businesses to identify, assess and address human rights risks in their operations and supply chains.
For businesses, this represents a more fundamental change than an extension of existing modern slavery reporting requirements. It aligns the UK more closely with international standards of responsible business conduct and will require large businesses to take a more active approach to identifying and addressing human rights risks, managing their business relationships and ensuring their due diligence arrangements work in practice.
Although the detail of the legislation is still to come, the announcement gives businesses a clear reason to review their existing human rights due diligence arrangements and consider where improvements may be needed.
What is the UK proposing?
The proposed legislation would introduce mandatory human rights due diligence for UK businesses with a global turnover of more than £350 million, and non-UK businesses generating more than £350 million in turnover in the UK.
It would cover services across the UK and goods in Great Britain, requiring businesses within scope to identify, assess and address human rights abuses and labour exploitation risks in their own operations and supply chains. The Government says the regime will be risk-based and proportionate, and aligned with established international standards, including the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Responsible Business Conduct.
The proposed turnover threshold reflects the Government’s intention to focus on the largest businesses, which it considers best placed to manage supply chain risks. However, the impact may extend further as companies within scope review their relationships with suppliers and other business partners. The proposed UK turnover threshold is considerably lower than that of the CSDDD, and to date there is no employee threshold.
The proposals include powers for a regulator to investigate businesses suspected of placing goods made with forced labour on the Great Britain market and, where forced labour is identified and due diligence obligations have not been met, direct their withdrawal. In Northern Ireland, the EU Forced Labour Regulation will apply under the Windsor Framework.
The Government aims to bring the measures into effect alongside the EU Forced Labour Regulation in December 2027. However, much of the detail remains to be developed. The regulator has not yet been identified, and the Government has not explained how turnover thresholds will be calculated or set out the wider enforcement arrangements and potential sanctions for failing to meet the new due diligence obligations. Legislation is expected to be introduced as soon as parliamentary time allows. We will continue to follow developments and provide updates as the details are published.
Moving beyond the Modern Slavery Act
The proposal represents a welcome development in the UK’s approach to business and human rights. When introduced in 2015, the Modern Slavery Act (MSA) was widely regarded as pioneering. However, the Government’s own review found that the UK’s approach to preventing forced labour remained fragmented and overly reliant on voluntary action and reporting.
Since then, international expectations have moved on. The UNGPs and OECD Guidelines have established a more comprehensive approach to responsible business conduct, focused on identifying, preventing and addressing adverse impacts on people. Mandatory due diligence laws in other jurisdictions have begun to make these expectations a legal requirement.
The proposed legislation brings the UK’s approach closer to that of other major trading economies. It also builds on the planned strengthening of Section 54 of the MSA through the Immigration and Asylum Bill.
How does the UK proposal compare with international requirements?
In the EU, the Corporate Sustainability Due Diligence Directive (CSDDD) requires companies within its scope to identify and address adverse human rights and environmental impacts across their own operations, subsidiaries and chains of activities. Its revised scope is based on a threshold of 5,000 employees and €1.5 billion worldwide turnover for EU companies, or €1.5 billion turnover in the EU for non-EU companies. The proposed UK legislation will focus on human rights abuses and labour exploitation, with no explicit environmental due diligence requirement.
The EU has also introduced specific legislation on forced labour. The EU Forced Labour Regulation (EUFLR), which applies from December 2027, prohibits products made with forced labour from being placed on, made available on or exported from the EU market, regardless of where they are made. It does not introduce a general human rights due diligence or reporting obligation. Instead, it gives authorities powers to investigate products suspected of being made with forced labour and prohibit them from entering or remaining on the market.
The UK’s proposed withdrawal powers have a similar objective to the EUFLR but make withdrawal conditional on two findings: that forced labour has been identified in the goods and that the business has failed to meet its due diligence obligations. This links the removal of goods from the Great Britain market directly to compliance with the proposed UK due diligence regime.
Other markets have also introduced measures to restrict goods made with forced labour. These include the US Uyghur Forced Labor Prevention Act, which creates a presumption that goods produced wholly or partly in China’s Xinjiang region, or by specified entities, are made with forced labour unless importers meet demanding evidential requirements. Canada also prohibits the import of goods produced using forced labour.
For businesses operating across multiple markets, the challenge is to understand where these requirements differ and where they overlap. A consistent, risk-based approach to human rights due diligence, grounded in internationally recognised standards, can provide a common foundation for meeting applicable obligations and also ensuring best practice is followed.
What businesses should be doing now
Although the detail of the proposed UK legislation is still to come, businesses should use the announcement as an opportunity to review their existing human rights due diligence arrangements. This is particularly relevant to companies that may fall within the proposed scope, as well as those operating across jurisdictions with different regulatory requirements.
The starting point should be understanding the most significant human rights risks associated with the business. This means looking beyond direct operations and immediate suppliers to consider where impacts may arise further down the supply chain and through other business relationships. Assessments should reflect the countries, sectors and operating conditions in which the business is involved, and take account of the perspectives of affected workers and other stakeholders
Businesses should then consider how effectively their existing arrangements translate identified risks into action. Do assessment findings inform procurement and operational decisions? Are responsibilities for addressing risks clear across relevant functions? Do monitoring, stakeholder engagement and grievance mechanisms provide reliable insight into conditions on the ground and whether remedial action is working?
Finally, businesses should consider whether senior management has sufficient oversight of the most significant human rights risks and whether there are clear processes for responding when problems are identified.
The priority is not to anticipate every detail of the forthcoming legislation, but to understand what existing arrangements achieve, where they fall short and what needs to improve.
Building a consistent approach to due diligence: how GoodCorporation can help
The Government’s intention to align the new regime with the UNGPs and OECD Guidelines provides a useful foundation for businesses. These internationally recognised standards offer a common approach to human rights due diligence that can help companies respond to different regulatory requirements while maintaining a consistent approach across their operations and supply chains.
GoodCorporation helps businesses assess and strengthen their human rights due diligence arrangements against these standards and relevant legislation. Our work examines how responsibilities are assigned, how risks are identified and assessed, and whether policies, processes and controls lead to appropriate action in practice. This includes considering whether businesses understand the perspectives and needs of affected rightsholders and whether identified impacts are being addressed effectively.
Our Human Rights Governance Framework, together with our Communities and Labour Rights frameworks, provides a practical structure for assessing the design and implementation of human rights programmes and identifying where improvements are needed.
As the UK proposals develop, businesses that understand the strengths and limitations of their existing arrangements will be better placed to respond. The objective should be to establish due diligence that identifies and addresses human rights impacts in practice, rather than treating each new regulatory requirement as a separate compliance exercise.
To find out more about our human rights work, visit our website or contact us to discuss how we can test and strengthen your existing arrangements.
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