What the proposed UK forced labour framework could mean for businesses
GoodBlog | read time: 7 min
Published: 10 February 2026
The UK could soon move from a transparency-based modern slavery regime to a mandatory human rights due diligence framework with civil liability, trade bans and significant financial penalties. If adopted, the proposed reforms would represent the most substantial shift in UK business and human rights regulation since the Modern Slavery Act 2015.
At the end of 2025, the Independent Anti-Slavery Commissioner (IASC) published a proposal to strengthen the UK’s forced labour and human rights legislative framework. The proposal sets out a blueprint for introducing mandatory human rights due diligence and stronger compliance requirements into UK law, aimed at tackling forced labour and serious human rights abuses across global supply chains. The proposal suggests that these changes are included in the upcoming legislative programme through the King’s Speech in May 2026, meaning that the reforms could come into force relatively soon.
If adopted, the changes would significantly strengthen the UK’s current approach and bring domestic law more closely in line with emerging international standards. Governments worldwide are moving away from voluntary, transparency-only regimes towards enforceable due diligence obligations. The EU, the United States and Canada have introduced new forced labour and human rights legislation, while Australia, New Zealand and South Korea are considering similar reforms. The UK’s proposed framework reflects this global shift.
Why change is needed
Labour exploitation remains a major challenge in global supply chains. According to Eleanor Lyons, the UK Independent Anti-Slavery Commissioner, more than 27 million adults and children are trapped in forced labour worldwide. These abuses often occur deep within complex supply chains, far from end markets but closely connected to the goods and services on which businesses rely.
The UK imports nearly £20 billion worth of goods each year that are at risk of being produced using forced labour. As other jurisdictions strengthen their laws, the UK risks becoming a dumping ground for goods barred elsewhere. The IASC warns this could leave British businesses exposed and potentially undercut by competitors operating in markets with clearer, more robust rules.
Throughout the development of the proposal, the IASC consulted extensively with UK businesses, which are increasingly aware of the risks that human rights abuses pose to their operations and broadly supportive of regulatory reform that adds clarity and creates a level playing field. Clearer rules would help UK companies remain competitive as global standards evolve, while supporting growth driven by innovation and responsible business practices.
From world leading to falling behind
When introduced in 2015, the Modern Slavery Act was rightly considered world-leading. It helped shine a spotlight on forced labour risks and brought the issue firmly onto boardroom agendas. Since then, however, the global landscape has changed rapidly. Other European jurisdictions, including the EU and Germany, have moved beyond reporting requirements to introduce mandatory due diligence and enforceable obligations through legislation such as the EU Forced Labour Regulation (2024) and the German Supply Chain Act (2023) . Indonesia, Thailand and South Korea are also currently in the process of drafting similar due diligence legislation.
While the UK has taken steps to respond, the IASC argues that the current approach has evolved into a “complex patchwork of disjointed laws”, spanning general reporting duties, sector-specific due diligence regimes, procurement rules, and voluntary international standards. This fragmentation makes compliance harder to navigate and risks leaving the UK with weaker, less coherent protections than its international partners.
Building on calls from the Business and Trade Select Committee and the Joint Committee on Human Rights, the IASC therefore makes the case for substantial reform. Modernisation is not only about addressing harm, but about aligning the UK with emerging international standards, providing legal certainty for responsible businesses, and helping to raise human rights protections across global supply chains.
What is being proposed
The proposal recommends the introduction of a UK Forced Labour and Human Rights Bill. The Bill would:
- Establish a statutory human rights due diligence framework
- Introduce civil liability for serious human rights harm
- Strengthen enforcement and reporting obligations
- Introduce a forced labour import and export ban
While the proposal does not explicitly define which businesses would fall within scope, it is likely that any threshold would align with the Modern Slavery Act 2015, which applies to organisations operating in the UK with an annual turnover of more than £36 million.
Liability for serious human rights harm
The proposed Bill would create civil liability where serious human rights harm is linked to a company’s operations or business relationships. A company may be held responsible if it causes or contributes to such harm, or if the harm is directly connected to its operations, products, or services through its value chain, including indirect suppliers and partners.
Liability would extend beyond the UK and could apply to adverse human rights impacts occurring anywhere in a global supply chain. Multiple organisations may be held jointly responsible, reflecting the shared obligations inherent in complex commercial relationships.
The framework is based on a due diligence standard rather than strict liability. Companies can rely on a defence if they can demonstrate that they took “reasonable measures” to identify, prevent, mitigate, and, where necessary, remediate harm. Assessments of due diligence would consider proportionality, the nature of the risk, the company’s leverage over its business relationships, and the effectiveness of actions taken.
Whether harm is considered serious would be assessed based on its scale, scope, and remediability, in line with best practice. The focus is on significant adverse impacts that materially impair recognised human rights, wherever they occur in the value chain.
Mandatory human rights due diligence
Building on the liability framework, the Bill would require organisations to implement a formal human rights due diligence programme. Companies would be expected to implement proportionate processes to identify, assess, and address human rights risks across their operations and value chains. In line with the OECD human rights due diligence steps, this includes taking steps to prevent and mitigate adverse impacts, monitoring the effectiveness of those measures, providing remediation where harm occurs, and communicating publicly on their due diligence activities.
This due diligence requirement is directly linked to the liability regime. Organisations that can demonstrate reasonable and proportionate due diligence will be able to rely on it as a defence against any claim of liability. The proposed framework, therefore, shifts the emphasis from disclosure alone to active, evidence-based risk management, ensuring that human rights impacts are systematically addressed rather than reported superficially.
Together, these provisions create a cohesive system where liability incentivises meaningful risk management, and due diligence provides both a practical roadmap and legal protection for companies operating in complex, global supply chains.
A proposed forced labour import and export ban
The Bill would also introduce a UK forced labour import and export ban, prohibiting goods made wholly or partly with forced labour from being imported to or exported from the UK.
Unlike the United States and Canada, the UK currently has no standalone prohibition on the import of goods produced with forced labour. Similar measures are also being finalised at EU level, as the EU Forced Labour Regulation is set to be applied to businesses from 14 December 2027. Without such powers, the UK risks becoming a weak link in global efforts to remove forced labour from supply chains.
Under the proposal, authorities would have the power to investigate forced labour risks, require companies to provide evidence about their supply chain management, and take enforcement action where goods are reasonably suspected of being produced with forced labour. This would place a new mandatory obligation on companies to trace supply chains, assess risks, and demonstrate that robust due diligence operates in practice.
Strengthening reporting by replacing Section 54 of the Modern Slavery Act
The Bill proposes replacing the current reporting regime under Section 54 of the Modern Slavery Act, which governs modern slavery statements. While Section 54 has helped raise awareness, it has been widely criticised for weak enforcement, inconsistent reporting quality, and an overemphasis on disclosure rather than demonstrable risk management.
Under the proposed approach, the existing requirement to publish an annual modern slavery statement would be removed and replaced with a single obligation for companies to submit an annual human rights due diligence statement through an online platform. This would create a standardised and accessible record of compliance, with reporting directly linked to an organisation’s due diligence processes and actions rather than treated as a standalone exercise. Importantly, reporting would no longer be an end in itself but would serve as evidence of how organisations are identifying, preventing, and addressing forced labour and human rights risks in practice.
Proposed penalties and criminal liability
To give the framework real impact, the proposal includes stronger enforcement mechanisms. Civil penalties could be imposed on organisations that fail to meet due diligence or reporting obligations, including the annual online statement. In serious cases where companies fail to take reasonable steps to prevent severe harm, they would face fines of up to 5% of global turnover and be required to pay the cost of any investigation. Furthermore, criminal liability could apply to responsible individuals, reinforcing senior-level accountability and embedding human rights into corporate governance.
What this means for business
While the proposed reforms raise expectations, they also provide clarity and reward responsible behaviour. Clear legal standards and a consistent framework would help businesses understand compliance requirements, reduce uncertainty, and create a fairer competitive environment. For companies already embedding human rights due diligence into governance and risk management, the changes formalise practices that are increasingly essential, and in many cases, are already in development.
The IASC framework signals a shift from reporting on risks to actively managing and preventing harm. Businesses should start aligning processes with the proposed statutory requirements, ensuring risk management, remediation, and reporting are demonstrably effective and defensible.
Our services include:
Human rights impact assessments and risk mapping: Identifying and assessing human rights and forced labour risks across operations and supply chains.
Gap analysis and governance design: Evaluating policies, procedures, and governance structures to ensure effective oversight and compliance with human rights due diligence legislation and best practice
Policy and practice development: Designing practical policies and processes to embed human rights due diligence throughout the organisation.
Training and capacity building: Tailored training for staff and suppliers to raise awareness and foster a culture of responsible business conduct.
Monitoring, reporting, and disclosure support: Helping organisations track effectiveness, report transparently, and meet statutory requirements.
By combining strategic insight with practical tools, GoodCorporation helps businesses not only comply with regulatory requirements but also embed responsible practices that enhance resilience, reputation, and long-term value.
While the proposed UK legislation may take some time to come into force, many companies are already looking at their human rights and forced labour obligations to comply with legislation in other jurisdictions where they operate. Whatever the final timeframe, this is clearly the direction of travel. To learn more about how your organisation can implement best practice and to access guidance on human rights impact assessments, risk mapping, due diligence, and reporting, visit our human rights service pages or contact us to speak to a member of our human rights team.
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