November 5, 2026

The United Kingdom has announced plans to introduce mandatory human rights due diligence legislation, potentially creating significant new compliance obligations for large domestic and international businesses.
Announced on November 4, 2026, the proposal would require companies to actively identify, assess, and address human rights abuses and labour exploitation throughout their operations and supply chains.
The announcement signals an important shift in the UK's regulatory approach, moving beyond transparency reporting toward legally enforceable corporate due diligence obligations.
Which Companies Would Be Affected?
The proposed legislation would apply to:
UK businesses with annual global turnover exceeding £350 million.
Non-UK businesses generating more than £350 million in annual turnover within the UK.
This distinction is particularly important for multinational companies. Businesses headquartered outside the UK could face new obligations if their UK-generated revenue exceeds the proposed threshold.
The government intends to cover services across the entire UK and goods in Great Britain, with separate arrangements for goods in Northern Ireland.
Moving Beyond Modern Slavery Reporting
Under Section 54 of the UK's Modern Slavery Act 2015, qualifying businesses with annual turnover of at least £36 million must publish an annual statement describing their efforts to address modern slavery risks.
The proposed legislation would go further by introducing an affirmative obligation to conduct human rights due diligence.
Companies would be expected to identify potential human rights violations, evaluate supply chain exposure, and take appropriate action to address identified risks.
The framework would align with established international standards, including the Organisation for Economic Co-operation and Development (OECD) Guidelines for Responsible Business Conduct and the United Nations Guiding Principles on Business and Human Rights.
Stronger Enforcement Against Forced Labour
The government also plans to introduce new enforcement powers targeting goods produced using forced labour. Under the proposed framework, a regulator could investigate businesses suspected of placing such products on the Great Britain market and require their withdrawal where forced labour is identified and due diligence obligations have not been met.
Northern Ireland is expected to apply the European Union's Forced Labour Regulation under the Windsor Framework. Together, these measures would strengthen the UK's ability to address forced labour risks associated with international supply chains.
What Businesses Should Prepare For
Although the legislation has not yet been introduced, potentially affected companies should begin evaluating their existing human rights compliance programs.
Priority areas include reviewing supplier risk assessments, identifying gaps in human rights due diligence procedures, and evaluating whether existing procurement and compliance systems can support more extensive monitoring and corrective action.
The government has indicated that it aims to align implementation with the EU's forced labour rules in December 2027. However, important details remain unresolved, including the final legislation, enforcement framework, penalties, and implementation timetable.
Notably, the current announcement focuses on human rights rather than introducing a broader environmental due diligence obligation.
The Bigger Picture
The UK's announcement reflects a broader international movement toward greater corporate accountability for human rights risks across global supply chains.
For multinational companies, the growing number of overlapping requirements makes it increasingly important to maintain a coordinated approach to regulatory monitoring, supplier oversight, and compliance documentation.
The takeaway: Companies with substantial UK operations should monitor this proposal closely and begin assessing whether their existing human rights due diligence processes would satisfy the anticipated requirements.

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