Mandatory human rights due diligence is a legal duty that will require the UK's largest businesses to check their operations and supply chains for human rights abuses and labour exploitation, assess the risks they find, and act on them. The UK government announced on 4 November 2026 that it will legislate to introduce the duty, replacing a system that has relied mainly on voluntary action and public reporting. The duty is not yet in force: no Bill has been published, no regulator has been named, and no start date has been set. This explainer sets out what the new regime is, which businesses it will catch, what they will have to do, how goods made with forced labour will be dealt with, and how the UK plan compares with the law in the European Union. ## What is mandatory human rights due diligence? Human rights due diligence is the process of identifying, assessing and addressing the risk that a business's operations or supply chains involve human rights abuses or labour exploitation, including forced labour. It means looking beyond a company's own offices and factories to the suppliers, subcontractors and raw materials behind its products and services, finding where workers may be at risk, and taking action to prevent or fix the harm. The word "mandatory" is what makes the announcement significant. At present, large UK businesses are mainly required to be transparent about what they do: under the Modern Slavery Act 2015, they must publish a statement about the steps they take to prevent modern slavery in their supply chains. The new regime goes further. It will require businesses in scope to actually carry out due diligence and address the risks they find, rather than only reporting on their efforts. As the law firm [Fieldfisher](https://www.fieldfisher.com/en/services/regulatory/public-regulatory-law-blog/uk-human-rights-due-diligence-and-forced-labour-law-how-does-it-compare-with-the-eu) puts it, the proposals "represent a significant change in the UK's approach to responsible business conduct", moving from transparency and voluntary action towards a duty to identify, assess and address risks. The duty will be risk-based and proportionate, and it will align with established international standards: the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights. Those standards already shape how many large companies manage supply chain risk, which is why the government says the regime will reflect how responsible businesses already manage risk. ## What did the UK government announce on 4 November 2026? The announcement came in a written ministerial statement to Parliament on 4 November 2026 by Jonathan Reynolds, Secretary of State for Business, Innovation, Science and Trade. The statement reported the outcome of the government's review of responsible business conduct, a review promised in the Trade Strategy, and set out the action the government proposes to take. The review found that the UK's current framework for preventing forced labour is fragmented and overly reliant on voluntary action and reporting. The Modern Slavery Act 2015 was world leading when it was introduced, the statement said, but international standards and legislative practice have since moved on, leaving the UK out of step with G7 partners and other major trading economies. Plans to strengthen the Modern Slavery Act through the Immigration and Asylum Bill are described as an important step, but the government concluded that further action is needed. The government therefore announced that it will legislate to introduce a mandatory human rights due diligence regime across the UK for services, and in Great Britain for goods. Alongside the duty, it will introduce powers to remove goods made with forced labour from the Great Britain market. It will also establish a centralised responsible business conduct guidance hub on GOV.UK, bringing together guidance, tools and templates in one place. The statement says the government will work with stakeholders on the design and implementation of the measures and introduce them as soon as parliamentary time allows. The full text of the statement is published by [UK Parliament as House of Commons Written Statement HCWS454](https://commonsbusiness.parliament.uk/Document/108782/Pdf?subType=Standard). ## Which businesses will be in scope? The regime is aimed deliberately at the largest businesses only. The government says only the largest businesses, with the capability and leverage to manage risks within their supply chains, will be in scope. The proposed thresholds are: | Business type | Turnover threshold | |---|---| | UK businesses | Global turnover of more than £350 million | | Non-UK businesses | UK-generated turnover of more than £350 million | That means an overseas business can be caught by the UK law even if it is incorporated elsewhere, as long as the turnover it generates in the UK passes £350 million. Small and medium-sized businesses will not be directly in scope, although they may feel the effects indirectly when large customers ask them for information about their own supply chains. The announcement does not yet explain precisely how the turnover tests will apply, including to corporate groups, and it does not set out in detail how the territorial scope of the due diligence obligation will operate. Those questions will need to be settled as the legislation is developed, according to [Fieldfisher](https://www.fieldfisher.com/en/services/regulatory/public-regulatory-law-blog/uk-human-rights-due-diligence-and-forced-labour-law-how-does-it-compare-with-the-eu). ## What will businesses have to do? Businesses within scope will be required to identify, assess and address risks of human rights abuses and labour exploitation within their operations and supply chains. The duty is framed in terms of human rights abuses and labour exploitation generally, rather than being confined to forced labour alone. The precise steps businesses must take have not yet been specified, and the announcement gives no document list, reporting template or fixed procedure. What the government has said is that the regime will be risk-based and proportionate, that it will prioritise action over unnecessary paperwork, and that it will align with the OECD Guidelines and the UN Guiding Principles. In practice, that points towards a familiar sequence: map supply chains, identify the highest-risk areas, assess the risks, take action to prevent or mitigate them, track whether the action works, and be able to show what was done. The government has also said it will establish a centralised guidance hub on GOV.UK, bringing together guidance, tools and templates. That hub is intended to support businesses, particularly those developing due diligence processes for the first time. ## What happens to goods made with forced labour? Alongside the due diligence duty, the government will introduce powers to remove goods made with forced labour from the Great Britain market. A regulator will be empowered to investigate businesses suspected of placing such goods on the market and, where due diligence obligations have not been met and forced labour is identified, direct their withdrawal. That structure matters, because it links the market power to the due diligence duty. As [Fieldfisher](https://www.fieldfisher.com/en/services/regulatory/public-regulatory-law-blog/uk-human-rights-due-diligence-and-forced-labour-law-how-does-it-compare-with-the-eu) notes, the EU's Forced Labour Regulation imposes an absolute ban on any product of forced labour, an obligation of result rather than an obligation of due diligence. The UK ministerial statement suggests the regulator's withdrawal power will depend on the business having failed to meet its due diligence obligations. If that is how the legislation is drafted, it would be an important difference between the regimes: a business that has carried out proportionate due diligence would have a defence that does not exist under the EU regulation. The government has not yet identified which regulator will exercise these powers, and it has not set out the wider sanctions available for non-compliance, or whether the legislation will create a civil liability regime or other routes to remedy. Those are among the substantial questions still to be answered about enforcement. ## What about Northern Ireland? Northern Ireland is treated differently for goods. The due diligence regime will apply across the UK for services, and in Great Britain for goods. In Northern Ireland, the government will apply the EU's Forced Labour Regulation under the Windsor Framework instead of the new UK goods powers. The ministerial statement says both regimes ensure goods made with forced labour can be withdrawn from the market and aim to deliver a similar effect in practice. ## How is this different from the Modern Slavery Act? The Modern Slavery Act 2015 requires large commercial organisations operating in the UK, with turnover of £36 million or more, to publish an annual statement setting out the steps they have taken to ensure modern slavery is not taking place in their business or supply chains. It is a transparency duty: a business can comply by publishing a statement, even if the statement says it has taken no steps. The new regime is different in two ways. First, the threshold is far higher, at £350 million of turnover, so far fewer businesses will be in scope. Second, the obligation is substantive rather than only about disclosure: businesses in scope must identify, assess and address risks, and a regulator will be able to investigate and direct the withdrawal of goods where due diligence obligations have not been met and forced labour is found. The government has also said it plans to strengthen the Modern Slavery Act's reporting requirements through the Immigration and Asylum Bill, so the two regimes will sit alongside each other rather than one replacing the other. ## How does the UK plan compare with the EU? The UK proposals bring the country closer to the European Union, where the Forced Labour Regulation and the Corporate Sustainability Due Diligence Directive, known as the CSDDD, will apply from 2027 and 2029 respectively. Like the CSDDD, the UK due diligence obligation will be based on the UN Guiding Principles and the OECD Guidelines, which should help businesses that are already building systems to comply with the EU rules. There are important differences. The UK's proposed threshold of £350 million is relatively low compared with the CSDDD's €1.5 billion, potentially bringing a larger number of additional companies within scope. On the other hand, the UK's forced labour powers appear to depend on a failure of due diligence, while the EU regulation imposes an absolute ban. It also remains to be seen whether the UK duty will cover environmental rights, such as the right to a clean and healthy environment, an issue that was a major source of contention during the passage of the CSDDD, and whether the UK will follow the CSDDD's prescriptive approach or give businesses more freedom to apply the international standards to their own circumstances, as Norway has done. ## When will the law take effect? There is no fixed implementation date. The announcement is a commitment to legislate, not draft legislation. The government has said it will work with stakeholders on the design and implementation of the measures and introduce them as soon as parliamentary time allows. [Fieldfisher](https://www.fieldfisher.com/en/services/regulatory/public-regulatory-law-blog/uk-human-rights-due-diligence-and-forced-labour-law-how-does-it-compare-with-the-eu) estimates that, based on the time taken to develop and enact broadly comparable legislation such as the Modern Slavery Act 2015 and the Economic Crime and Corporate Transparency Act 2023, Royal Assent could be approximately 12 to 24 months away, although that will depend on when a Bill is introduced, the priority given to it and the extent of parliamentary scrutiny. For now, nothing changes at a UK border and no new duty applies to any business. What has changed is the direction of travel: the government has committed to legislate, and [Fieldfisher](https://www.fieldfisher.com/en/services/regulatory/public-regulatory-law-blog/uk-human-rights-due-diligence-and-forced-labour-law-how-does-it-compare-with-the-eu) notes there is general cross-party support for measures of this kind. ## What should businesses do now? Businesses that may be in scope do not need to wait for the legislation before considering their readiness. Because the government has said expressly that the regime will align with the UN Guiding Principles and the OECD Guidelines, businesses can begin by reviewing their existing human rights risk-management processes against those standards, including how they identify risks in their operations and supply chains and how identified risks are addressed and documented. Where there are endemic issues in particular supply chains that cannot be addressed through due diligence, businesses should consider whether alternative supply chains are available. ## Frequently asked questions **Is mandatory human rights due diligence law in the UK yet?** No. On 4 November 2026 the government announced that it will legislate to introduce a mandatory human rights due diligence regime. No Bill has been published, no regulator has been named, and no start date has been set. **Which businesses will the new duty apply to?** UK businesses with global turnover of more than £350 million, and non-UK businesses with UK-generated turnover of more than £350 million. Smaller businesses will not be directly in scope. **What will businesses in scope have to do?** They will be required to identify, assess and address risks of human rights abuses and labour exploitation within their operations and supply chains, in a way that is risk-based and proportionate and aligned with the OECD Guidelines and the UN Guiding Principles. **Can goods made with forced labour be removed from sale?** Yes, under the plan. A regulator will be empowered to investigate businesses suspected of placing goods made with forced labour on the Great Britain market and, where due diligence obligations have not been met and forced labour is identified, direct their withdrawal. **Does the new regime apply in Northern Ireland?** For services, yes, the due diligence regime will apply across the UK. For goods, Northern Ireland will instead apply the EU's Forced Labour Regulation under the Windsor Framework. **How is this different from the Modern Slavery Act?** The Modern Slavery Act requires large businesses to publish a statement about the steps they take against modern slavery. The new regime will require businesses in scope to actually carry out due diligence and address the risks they find, with a regulator able to act where they do not.