What you need to know
- On 4 November 2026 the UK government announced its intention to introduce a mandatory human rights due diligence regime (mHRDD) across the UK for services, and additionally in Great Britain for goods.
- The largest UK and overseas businesses will have a legal duty to identify, assess and address human rights risks in their operations and supply chains, with a December 2027 target.
What you need to do to prepare
- Follow the proposals, and participate in the stakeholder engagement to help shape the legislation. Understanding the key principles contained in international standards which will inform the content of the legislation will assist with this.
- Consider the extent to which your organisation already assesses and addresses risks of human rights abuses and labour exploitation within operations and supply chains, and consider any gaps which will require attention.
- Separately, the UK is also proposing amendments to the Modern Slavery Act 2015 (MSA). Consider the amended guidance to s. 54 of the MSA. Be ready for these changes, which will strengthen the UK's modern slavery disclosure and reporting regime.
What is the background to this?
The UK has faced calls to strengthen its laws on business and human rights for a number of years. The MSA was world-leading when it came into force 11 years ago, requiring corporations with £36 million or more in annual turnover to report what they had done to address modern slavery in their supply chains each year. But the Act is limited in scope, and compliance with its reporting obligation has been mixed.
In its June 2025 Trade Strategy, Keir Starmer's government framed responsible business conduct as part of its mission to grow the UK economy, arguing that championing international standards and frameworks on human rights would support a level playing field for British businesses. It committed to review the UK's approach to responsible business. Separately, in December 2025, the UK's Independent Anti-Slavery Commissioner published model legislative drafting on human rights due diligence.
All this occurred against the backdrop of developments in other jurisdictions, most notably the EU's 2024 Corporate Sustainability Due Diligence Directive (CS3D). That legislation has undergone a number of developments, most recently following the First Omnibus Package Content Directive, which simplified the legislation and reduced its scope. But it raised the expectation that the UK would legislate in this space.
What has the UK announced?
The UK has provided little detail. Its statement says that:
- The legislation will apply across the UK for services, and in Great Britain for goods. (In Northern Ireland, the EU's Forced Labour Regulation will be applied under the Windsor Framework).
- The legislation will only directly apply to UK businesses with a global turnover of over £350 million, as well as non-UK businesses with a UK-generated turnover of over £350 million.
- Businesses will be required to identify, assess and address risks of human rights abuses and labour exploitation within their operations and supply chains.
- The regime will be risk-based, proportionate and align with international, non-binding, standards, including the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.
- A regulator will be empowered to remove goods made with forced labour from the Great Britain market, 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 their withdrawal.
- Centralised responsible business conduct guidance will bring together guidance, tools and templates in a single location.
When will this happen?
The UK's statement says there will be engagement on the design and implementation of the measures, and they will be introduced "as soon as parliamentary time allows." An accompanying written statement says that the aim is for the measures to take effect in December 2027 (to coincide with the application of the Forced Labour Regulation in the EU and Northern Ireland).
Will the UK cover the same subjects as CS3D?
CS3D is broad, requiring companies to identify and address adverse human rights and environmental impacts in their due diligence. There is no suggestion in the UK's statement that environmental compliance will be a specific area of focus. In reality, though, human rights and environmental risks often overlap. The OECD's Guidelines for Responsible Business Conduct, for example, contain provisions addressing environmental impacts, with amendments in 2023 introducing climate change concepts.
Could businesses have to comply with UK legislation and CS3D?
Yes, businesses to which the UK legislation and CS3D apply will have to comply with both laws. The simplified CS3D will apply to EU entities with, on average, over 5,000 employees and net annual turnover of over EUR 1.5 billion. Non-EU entities will be in-scope where their net turnover derived from EU business exceeds EUR 1.5 billion. These thresholds are materially higher than the £350 million threshold proposed by the UK government.
Will the UK legislation lead to more complaints and litigation?
Claims arising from business and human rights issues have become more frequent in the past few years.
Claimants have pursued supply chain litigation in the English courts. In October 2026, the Financial Times reported that the UK Office for Responsible Business Conduct had "registered a sevenfold rise in complaints over firms’ conduct in five years, as companies come under growing pressure on environmental harms and labour abuses". The Office for Responsible Business Conduct is the UK's designated "national contact point" for complaints under the OECD Guidelines for Responsible Business Conduct.
The legislation should promote responsible practices that reduce the risk of claims. In the short term, though, claims arising from businesses' compliance (or non-compliance) with the new duties may arise.
The Independent Anti-Slavery Commissioner's 2025 model drafting included provisions on civil liability of persons responsible for serious human rights harm. We will see whether the government looks to address this aspect in the legislation, or leaves the question of civil liability for the courts to develop.
Will businesses below the turnover threshold be affected by the legislation?
Even businesses whose turnover falls below the applicable threshold are likely to be affected by the legislation, which will impact whole supply chains. Larger counterparties who are required to comply with the legislation will look to include in their contracts provisions which assist them in complying with their statutory obligations. These are likely to include information and audit rights, and compliance with policies clauses. It is not yet clear if the UK regime will incorporate provisions to limit such "trickle down" of obligations as the EU adopted in relation to the CS3D.
How should businesses prepare?
Businesses should:
- Follow the proposals regarding mHRDD legislation. The government has committed to "work closely with stakeholders on the design and implementation of these measures". By participating in the stakeholder engagement, you can comment on how the legislation is structured and share your experience of what has worked well, and less well, in other jurisdictions.
- Understand the key principles contained in international standards which will inform the content of the legislation. These include the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights, with which many larger businesses already seek to comply.
- Independent of the proposed legislation, be ready for likely upcoming changes to section 54 of the MSA (in the UK government's Immigration and Asylum Bill) to: (i) require more detailed supply chain due diligence disclosures in modern slavery statements (including on risk assessment processes and policies addressing identified risks), (ii) strengthen the board approval and director sign-off process, and (iii) introduce a new financial penalties regime, with fines of up to 1% of turnover for failure to publish a modern slavery statement. The Bill is going through Parliament and these changes to the MSA are likely to be adopted regardless of any mHRDD legislation. Read our briefing on the proposed amendments here.
- Consider the extent to which your organisation already assesses and addresses risks of human rights abuses and labour exploitation within operations and supply chains. Even if the legislation is not yet in effect, the direction of travel is clear. The legislative process will bring scrutiny to this area, and there is value in businesses getting ahead and conducting a proportionate review.
Please let us know if you would like to discuss the proposed legislation with our Sustainability experts.
Authors: Tom Cummins, Senior Counsel.
