UK Government Commits to Mandatory Human Rights Due Diligence Law: Outcome of the Responsible Business Conduct Review

By Sarah Bishop, Hannah Edmonds-Camara, Daniel Feldman, Elise Hartnett, Paul Mertenskötter, Mary Mikhaeel, Tom Plotkin, Ian Redfearn, Don Ridings & Emma Sawatzky on November 5, 2026

On November 4, 2026, the UK Government published a statement announcing the outcome of its responsible business conduct review (“RBC Review”), which it launched in its Trade Strategy 2025 (for background, please refer to our previous blog post here).

The Government found in the RBC Review that the UK’s current framework for preventing forced labor is “fragmented and overly reliant on voluntary action and reporting measures.” It also acknowledged that, while the Modern Slavery Act 2015 (“MSA”) was world-leading when introduced, international standards and legislative practice have since moved on, “leaving the UK out-of-step with G7 partners and other major trading economies.”

In this post, we summarize the Government’s commitments in response to these findings and what they mean for companies, as well as ongoing reforms to the MSA.

Key commitments

The Government committed to three core measures:

Mandatory human rights due diligence: The Government will legislate to require in-scope businesses to identify, assess, and address risks of human rights abuses and labor exploitation in their own operations and supply chains. The regime will be risk-based and proportionate, aligned with the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights. It will apply to UK businesses with a global turnover above £350 million, and non-UK businesses with UK-generated turnover above £350 million. This due diligence law will apply across the UK (including Northern Ireland) for services and in Great Britain (i.e., England, Scotland, and Wales) only for goods. (Rules around goods will be regulated differently in Northern Ireland, about which see below.)

Market-withdrawal powers for forced labor goods: Under the due diligence regime, a regulator will be empowered to investigate businesses suspected of placing goods made with forced labor on the Great Britain market and, where forced labor is identified and due diligence obligations have not been met, direct their withdrawal. In Northern Ireland, the EU Forced Labour Regulation (“FLR”) will apply under the Windsor Framework, which ensures that Northern Ireland generally aligns with EU law relating to the single market for goods. Further detail on the application of the FLR to Northern Ireland is set out in a Government policy paper, which was also published on November 4.

A centralized guidance hub: The Government will establish a responsible business conduct guidance hub on GOV.UK, bringing together guidance, tools, and templates in a single location.

Implications

The announcement marks a decisive move beyond the disclosure-based model of Section 54 of the MSA, which requires a transparency statement but imposes no due diligence obligations, toward legally required action backed by a regulator with enforcement powers. At the same time, the £350 million threshold is nearly ten times the MSA’s £36 million reporting threshold (though measured differently for non-UK businesses), confirming the Government’s focus on only the largest businesses with the capability and leverage to manage supply chain risks.

There is uncertainty about the details of any forthcoming regulation. In particular:

Timing: The statement does not explain when the Government will publish its detailed proposals, nor does it set out a legislative timetable. The Government has said it will work closely with stakeholders on design and implementation and introduce the measures “as soon as parliamentary time allows.”

Enforcement: Key ambiguities include the identity of the regulator(s) and any potential civil and/or criminal liability for violations of the law.

While many of the details are unclear, the UK Government’s apparent choice to combine both a human rights due diligence model and some kind of market ban/withdrawal mechanism suggests it may be attempting to bring some level of policy coherence between human rights due diligence and forced labor import ban regimes.

What about the planned MSA reform?

In addition to this new due diligence legislation, on June 30, 2026, the UK Government introduced proposed reforms to the MSA’s reporting regime in the Immigration and Asylum Bill, including mandatory disclosure categories and updated approval requirements. The reforms would also empower the Secretary of State to issue regulations that impose direct financial penalties for failure to comply with the modern slavery reporting regime without “reasonable excuse.”

Key takeaways

Companies might consider the following actions in light of the UK Government’s announcement:

Assess scope: Consider whether any entities are likely to meet the £350 million threshold for the due diligence law.

Track and consider policy engagement: Monitor legislative progress and opportunities for public consultation. There will likely be opportunities to engage with policy development and the legislative process. Companies might be particularly focused on seeking to maximize coherence between these incoming laws and existing, related regimes, including the UK MSA (and other modern slavery reporting laws), the EU Corporate Sustainability Due Diligence Directive (“CSDDD”), and EU FLR.

Review human rights due diligence processes: Given the indication that requirements will align with existing international standards, companies may consider beginning their review of human rights due diligence efforts (alongside preparations for CSDDD and FLR compliance, where applicable).

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