UK Mandatory human rights due diligence

The Government’s announcement signals a move from reporting human rights risks to requiring larger businesses to manage them.

Article summary

The UK Government has committed to introducing mandatory human rights due diligence legislation. The proposed regime would apply to large UK businesses and certain non UK businesses operating in the UK.

Companies would need to identify, assess and address human rights abuses and labour exploitation across their operations and supply chains. The legislation is still under development, and the final compliance timetable has not been confirmed.

“Businesses will increasingly need to show what they do about human rights risks, not only what they know about them.”

The announcement follows the Government’s Responsible Business Conduct Review. The review found that the existing UK framework was fragmented and too reliant on voluntary action and reporting.[1]

The Modern Slavery Act 2015 was an important step when introduced. The Government now considers that international standards and legislative practice have moved forward, leaving the UK framework out of step with other major economies.[1]

What the proposed legislation would require

The Government plans to introduce a mandatory human rights due diligence regime across the UK for services. For goods, the regime would apply in Great Britain.

The proposed requirements would cover large businesses with the scale and influence to manage human rights risks within their supply chains.

The scope would include:

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

Businesses within scope would need to identify, assess and address risks of human rights abuses and labour exploitation. The Government has stated that the regime would be risk based and proportionate.

It also intends to align the requirements with established international standards, including the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.[1]

This approach would place greater emphasis on practical action. Businesses would need to understand where risks arise, determine how serious those risks are, and demonstrate how they respond.

Separately, proposed reforms to the Modern Slavery Act would strengthen reporting requirements and introduce financial penalties for non compliance.

New powers concerning forced labour

The Government also plans to introduce powers to remove goods made with forced labour from the Great Britain market.

Under the proposed approach, a regulator would be able to investigate businesses suspected of placing such goods on the market. Where forced labour is identified and due diligence obligations have not been met, the regulator could direct the goods’ withdrawal.[1]

This would create a stronger connection between supply chain due diligence and market access. Businesses would need to consider whether their supplier controls can identify serious labour risks before products reach the market.

“The direction of travel is clear. Human rights due diligence will need to become part of business decision making and supply chain management.”

What businesses should consider now

The legislation has not yet been introduced, and its final requirements remain unknown. The Government has stated that it will introduce the measures as soon as parliamentary time allows.[1]

Businesses should therefore avoid assuming that current processes will meet future expectations. Large companies can begin by reviewing how they currently manage human rights and labour risks.

Useful early steps include:

• Mapping operations, suppliers and sourcing locations
• Identifying higher risk sectors, countries and activities
• Reviewing existing supplier standards and contracts
• Assessing how concerns are reported and investigated
• Checking whether remediation processes are clearly defined
• Recording evidence of decisions, actions and outcomes

These steps can help businesses understand their current level of preparedness. They can also make future regulatory requirements easier to implement once the legislation is finalised.

The announcement is especially relevant to companies operating across the UK and EU. For these businesses, it reinforces the importance of aligning supplier risk management with evolving requirements under the EU CSDDD and the EU Forced Labour Regulation. A coordinated approach can help companies identify overlapping expectations, strengthen supplier oversight and prepare for future implementation.

Moving from awareness to action

The proposed legislation marks a significant change in the UK’s approach to responsible business conduct. Human rights reporting will increasingly need to sit alongside evidence of risk assessment, prevention, action and remediation.

The Government’s announcement does not yet provide a final compliance framework. It does, however, establish a clear policy direction. Businesses that begin strengthening their due diligence capabilities now will be better placed to respond when the detailed requirements are published.

We help organisations assess human rights risks, map supply chains, review due diligence processes and develop practical remediation frameworks. To prepare for these changes, contact Nexio Projects to discuss your current approach and priority actions. Contact us for support!

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