Mandatory human rights due diligence is coming to the UK: What businesses need to know

On 4 November, the UK Government announced its commitment to legislate for mandatory human rights due diligence. While important details are still to be confirmed, the direction of travel is clear: businesses will be expected to take greater responsibility for identifying and addressing human rights risks across their operations and supply chains.

Here’s what we know so far.

What’s been announced?

The proposed legislation will require large businesses to identify, assess and address risks of human rights abuses and labour exploitation in their operations and supply chains, in line with the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.

A regulator will also be empowered to investigate businesses and, where forced labour is identified and due diligence obligations have not been met, direct the withdrawal of affected goods from the Great Britain market.

Who will be in scope?

The proposed requirements will apply to:

• UK businesses with global turnover above £350 million.
• Non-UK businesses with UK-generated turnover above £350 million.

Geographical scope: The requirements will apply to services provided across the UK, but to goods placed on the market in Great Britain only. Goods placed on the market in Northern Ireland will instead fall under the EU Forced Labour Regulation, which applies there under the Windsor Framework.

The proposals therefore have implications for large businesses operating internationally, as well as those supplying goods and services into the UK market.

What remains unclear?

There are still several important questions to be answered:

• Timing: Legislation will be introduced “as soon as parliamentary time allows”. The Government intends the measures to take effect alongside the EU Forced Labour Regulation in December 2027, although the precise implementation timetable remains to be confirmed.
• Penalties and enforcement: The regulator’s investigation and withdrawal powers have been outlined, but the full enforcement framework and any penalties are yet to be confirmed.
• Existing legislation: How the new requirements will interact with the Modern Slavery Act, including its planned reforms, remains to be clarified.
• Environmental impacts: The announced proposals focus on human rights and labour exploitation. Environmental due diligence is not included in the current proposals.
• Practical guidance: The Government has committed to establishing a centralised Responsible Business Conduct guidance hub on GOV.UK, bringing together guidance, tools and templates to help businesses understand and implement their due diligence responsibilities.

What does this mean for businesses?

The implications will extend beyond the largest companies directly covered by the proposals.

• For businesses in scope: Publishing a modern slavery statement will not be enough. Companies will need to demonstrate a robust, risk-based approach to identifying, preventing and addressing human rights impacts.
• For suppliers: Businesses below the proposed turnover threshold should also prepare for increased scrutiny. Larger customers are likely to seek more information and evidence about human rights risks and how they are being managed.
• For businesses preparing for EU requirements: The UK has indicated that its approach will align with the OECD and UN frameworks. Existing work on human rights due diligence should therefore provide a useful foundation.

A focus on meaningful action, not just compliance

The Government has indicated that it wants the new regime to encourage a proportionate, risk-based approach, prioritising meaningful action to address human rights risks rather than simply generating additional paperwork.

This is an important distinction. Effective human rights due diligence is not about producing policies or completing supplier questionnaires for the sake of compliance. It requires businesses to understand where their most significant risks lie, engage with affected stakeholders and take appropriate action to prevent and address harm.

Why start preparing now?

Effective human rights due diligence cannot be put in place overnight. Understanding supply chains, identifying the most significant human rights risks and assessing exposure to forced labour all take time.

Companies that start building this understanding now will be better positioned to respond when the legislation is finalised, as well as to meet the growing expectations of customers, investors and other stakeholders.

Waiting for the final legislation or Government guidance before taking action could leave businesses with significant work to do in a relatively short period.

How TDi Sustainability can help

At TDi Sustainability, we support businesses in developing and implementing practical approaches to human rights and responsible business conduct.

Our work includes:

• Human rights strategy and human rights due diligence
• Human Rights Impact Assessment (HRIA)
• Free, Prior and Informed Consent (FPIC)
• Forced labour risk identification and mitigation
• Responsible recruitment

We work with businesses to understand their human rights risks, strengthen their due diligence approaches and develop practical strategies to prevent, mitigate and address adverse human rights impacts across their operations and supply chains.

As expectations around human rights due diligence continue to evolve, we help businesses understand what is required, identify where action is needed and put effective processes in place.

Want to understand what the UK’s proposed legislation could mean for your business? Get in touch with our team to discuss how TDi Sustainability can support your human rights due diligence journey.

References:

Statement made on 4 November 2026 by the UK Government regarding human rights due diligence.