In brief
On 4 November 2026, the UK Government confirmed in a written ministerial statement that it will introduce mandatory human rights due diligence for UK businesses with global turnover above GBP 350 million and non-UK businesses with UK-generated turnover above GBP 350 million. Draft legislation and timing remain unclear, but businesses can start assessing readiness now, using work undertaken for the EU Corporate Sustainability Due Diligence Directive or EU Forced Labour Regulation as a starting point.
Key takeaways
- In-scope businesses will need to identify, assess and address human rights and labour exploitation risks in their operations and supply chains.
- The regime will cover services across the UK and goods in Great Britain. The EU Forced Labour Regulation will apply in Northern Ireland under the Windsor Framework.
- The framework will be risk-based and aligned with the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.
- A regulator will be able to investigate suspected forced-labour goods and, where due diligence duties have not been met and forced labour is identified, direct their withdrawal from the Great Britain market.
- The Government also intends to establish a centralised responsible business conduct guidance hub on GOV.UK.
In more detail
The Government has framed the new regime as a risk-based due diligence obligation rather than simply a reporting requirement. In-scope businesses will be expected to take steps to identify, assess and address human rights and labour exploitation risks across their operations and supply chains. The Government has said that the regime will prioritise action over unnecessary paperwork and align with established international standards, including the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.
Although details on the provisions remain to be confirmed, it seems clear that the UK rules will be aligned with the EU Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Forced Labour Regulation (EU FLR). In practice, this means that businesses that have already started working on due diligence policies and processes in preparation for the CSDDD and the EU FLR should consider how those processes could be leveraged for the UK regime to ensure consistency and avoid duplication of efforts.
A crucial difference between the UK announced proposal and the CSDDD is the exclusion of environmental impacts from the scope of the rule, which are in scope for CSDDD but do not seem to be in scope for the upcoming UK due diligence regime.
The announcement establishes the broad framework, but a number of important details will depend on the legislation and its implementation, including:
- When the new obligations will take effect and whether there will be transitional periods;
- The detailed scope of the due diligence obligations;
- Which regulator will oversee the regime and the extent of its investigatory and enforcement powers;
- Whether it will supersede the UK Modern Slavery Act obligations and co-exist with it; and
- The consequences of non-compliance beyond the announced power to withdraw forced-labour goods from the Great Britain market.
The Government has said that it will work with stakeholders on the design and implementation of the regime and will introduce the legislation as soon as parliamentary time allows. It also intends to establish a centralised responsible business conduct guidance hub on GOV.UK.
For specific advice on the proposed regime and to help your business prepare, please contact Tom Quincey, Gabrielle Galdino-Glaeser or Tatiana Kalaji.
Tatiana Kalaji, Associate, has contributed to this legal update.