In brief
- The UK Government says it will legislate for mandatory human rights due diligence. It isn’t law yet.
- It will apply to UK businesses with global turnover above £350 million, and to non-UK businesses with more than £350 million of UK-generated turnover.
- It will cover services across the UK and goods in Great Britain.
- A regulator would be able to direct the withdrawal of goods made with forced labour from the Great Britain market.
- There’s no start date. The Government says it will introduce the measures as soon as parliamentary time allows.
- Businesses below £350 million aren’t directly in scope, but buyers may pass requirements down the chain.
If you run responsible sourcing for a large business, this is one to follow closely. The announcement follows a government review that found the current approach to preventing forced labour fragmented and too reliant on voluntary action and reporting (UK Parliament).
Human rights due diligence is the process of identifying, assessing and addressing human rights and labour exploitation risks in your operations and supply chains. The legislation hasn’t been introduced, so much of the detail is still open. What the Government has set out is the direction, who it expects to bring into scope and the kind of due diligence it expects.
What has the Government announced?
The Government says the regime will apply across the UK for services and in Great Britain for goods. It will cover UK businesses with global turnover above £350 million, and non-UK businesses with more than £350 million of UK-generated turnover. Businesses in scope will have to identify, assess and address risks of human rights abuses and labour exploitation in their own operations and supply chains.
The regime is to be risk-based and proportionate, and aligned with the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights, the international standards most due diligence frameworks follow. In practice, that points to an ongoing process: identify risk, act on it, monitor what happens and be able to show how impacts were addressed.
Do businesses below £350 million need to pay attention?
Smaller businesses aren’t directly in scope. But the large businesses that are will need information from their suppliers, and some of that is likely to move down the chain as buyers ask for better evidence on labour practices, sourcing, subcontracting and corrective action. That would be a commercial effect rather than a legal obligation under the proposed regime. If you sell into larger businesses, watch how buyer requirements develop.
From reporting to action
Under the Modern Slavery Act, large businesses have mainly been required to disclose: an annual statement describing what they do. The proposed regime goes further by requiring businesses in scope to act on the risks they find.
For sourcing and supply chain teams, the practical question changes from “Have we reported what we’re doing?” to “Can we show how we identify risk, what we do when we find it and whether that action is working?” For many businesses, the first step is checking what their current due diligence produces as evidence.
Goods linked to forced labour could be withdrawn from the market
The Government also plans powers to remove goods made with forced labour from the Great Britain market. A regulator would be able to investigate businesses suspected of placing such goods on the market and, where forced labour is found and due diligence obligations haven’t been met, direct their withdrawal.
The withdrawal powers tie due diligence to market access, which raises the stakes for the evidence you hold on suppliers and production sites. A supplier questionnaire or an earlier audit can form part of it. Audits remain the foundation, and independent onsite verification is how you test whether what they recorded still holds, particularly where the evidence is weak, inconsistent or points to a serious concern.
Does it apply in Northern Ireland?
Not in the same way. In Northern Ireland, the Government says it will apply the EU Forced Labour Regulation under the Windsor Framework (UK Parliament). Like the proposed Great Britain powers, the regulation allows goods made with forced labour to be withdrawn from the market, and the Government says the two regimes are intended to have a similar effect in practice.
When will it take effect?
The Government hasn’t given a date. It says it will introduce the measures as soon as parliamentary time allows, and that it will work closely with stakeholders on design and implementation. For reference, the EU Forced Labour Regulation applies from 14 December 2027 to products placed on the EU market (EUR-Lex).
What should businesses review now?
You don’t need the final wording to test whether your current processes would stand up to a more active requirement. Four areas are central to established due diligence frameworks.
Visibility beyond Tier 1
Tier 1 visibility is often relatively strong. The picture thins out further up the chain. If a serious labour issue arose upstream, would you know which sites, labour providers or subcontractors were involved?
How risk is prioritised
Country and sector risk help, but they rarely tell the whole story. Recruitment models, migrant labour, subcontracting, production pressure and earlier findings all change the picture.
What your evidence rests on
When you decide a site is low risk, what are you relying on? Questionnaires and audit reports each add something, but their age and reliability matter too. Where a serious concern arises, be ready to go further.
Action and follow-up
When a significant finding comes in, who owns the response, is it escalated, and is the root cause understood? A finding marked as closed doesn’t by itself show the underlying issue is resolved. At Verisio, we don’t close a non-conformance on supporting documents alone: we ask the supplier to set out the root cause and the preventative measures. Businesses should also be able to show how they track repeat findings and decide when further onsite work is needed.
What we don’t know yet
- the legislative timetable
- how the £350 million threshold will be calculated in practice
- which regulator will oversee the regime, and what enforcement powers it will have beyond withdrawing goods
- how businesses will be expected to show compliance
- whether civil penalties or other sanctions will apply
- how the regime will sit alongside Modern Slavery Act requirements
- what guidance will follow for different sectors
The Government says it will set up a central responsible business conduct guidance hub on GOV.UK. Until the detail arrives, it’s wise not to treat any part of the proposals as settled.
What happens next
This is the start of the legislative process, not the end. For most businesses, the immediate job isn’t rebuilding a due diligence programme. It’s finding where the gaps are. If you’re at an earlier stage, start by mapping your highest-risk suppliers and the tier behind them.
Whatever the final wording, a regulator or a buyer will ask what you did and how you know it worked. That record builds over months of findings raised, fixed and checked, and it can’t be put together after the event.
Verisio can help you review where your supplier due diligence stands today, improve where the evidence needs strengthening and get ready for what’s coming. Talk to our team.
