Beyond the Modern Slavery Act: The UK’s Next Step on Forced Labour

On the 4th of November 2026, the UK Government confirmed plans to make human rights due diligence mandatory for large businesses and give a regulator the power to pull goods made with forced labour off the market.

The plans go further than the UK’s existing focus on disclosure and follow the Government’s Responsible Business Conduct Review, which concluded that the UK’s current approach to forced labour has fallen behind its major trading partners. 

Why the Government Is acting

The Responsible Business Conduct Review was launched under the 2025 Trade Strategy and found that the UK has relied largely on voluntary action and reporting to tackle forced labour in supply chains. The Modern Slavery Act 2015 remains the UK’s main legislation in this area. However, expectations have grown since its introduction, and the Government recognises that reporting requirements alone are no longer enough.

The focus now is on moving businesses from reporting on forced labour risks to actively addressing them.

The proposed measures

The proposed measures outline a targeted approach, prioritising changes that can be put into practice quickly and make a measurable difference. 

The measures outline mandatory human rights due diligence for businesses with turnover above £350m, whether UK based or measured on UK-generated turnover. In-scope businesses will need to identify, assess and address the risks of human rights abuses and labour exploitation, both within their own operations and across their supply chains.

The regime is designed to be risk-based and proportionate, meaning businesses will be expected to focus their efforts where the risks are greatest. 

The planned regime will also give a regulator power to investigate businesses suspected of selling goods made with forced labour in Great Britain. Where forced labour is found and due diligence obligations have not been met, the regulator will be able to order those goods to be withdrawn from the market. 

Keeping pace with global standards

Other major economies have already introduced stronger forced labour measures, and the Government’s proposals aim to bring the UK more closely in line with these international approaches.

In the EU, the Forced Labour Regulation will apply from 14th December 2027, banning products made with forced labour from the EU market. The United States already stops certain goods linked to forced labour at the border and, in July 2026, introduced additional Section 301 tariffs on countries it judged to have failed to adopt or effectively enforce forced labour import bans, including a 10% tariff on the UK.

As other markets close their doors to goods made with forced labour, there is a growing risk that those goods are redirected to countries with weaker controls. The UK Government has made clear that it wants to prevent this, so that products sold in the UK are not linked to exploitation.

What comes next

While the announcement sets out the Government’s intentions, work remains. Draft legislation has not been released and we are still awaiting formal timelines. The Government also needs to confirm which regulator will oversee the regime, what penalties will apply, and how the new requirements will fit alongside existing legislation like the Modern Slavery Act.

What is clear, however, is the direction of travel. The UK is moving into line with international standards on forced labour, and businesses should start preparing now.

As forced labour legislation continues to develop, the businesses best prepared will be those already taking steps to map their supply chains and verify the origin of their products. Those identifying risks early and acting on them will be in a better position to meet new requirements as they are introduced.

Image credit: Vecteezy