Measures to prevent modern slavery already exist in the UK, under the Modern Slavery Act 2015. But the existing framework mainly asks businesses that are eligible to report on what they have done to fight modern slavery, rather than require them to take specific steps to do their due diligence. The governmentโs review found that the current approach was fragmented and overly reliant on voluntary measures. It also highlighted the need for the UK to bring its approach closer to international standards and those adopted by other major economies. The announcement comes amid growing international scrutiny of goods produced using forced labour. Earlier in 2026, the United States introduced new tariffs on UK imports after raising concerns about the UK's enforcement of restrictions on such goods. The proposed law aims to address these concerns by requiring businesses to take a more active role in identifying and managing human rights risks throughout their supply chains.
Under the proposed regime, businesses within scope will be required to identify, assess and address risks of human rights abuses and labour exploitation across their operations and supply chains. The legislation is also expected to introduce enforcement powers, allowing a regulator to investigate businesses suspected of placing goods made with forced labour on the Great Britain market. Where forced labour is identified and due diligence obligations have not been met, the regulator will be able to direct the withdrawal of those goods. The framework is expected to align with established international standards, including the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights. However, the legislation has not yet been finalised, and further details on its implementation and specific requirements are still awaited.
The proposed law could change the way large companies work with their suppliers and make sourcing decisions. They will be expected to examine labour conditions at every stage of the supply chain and to take suitable action once a risk has been identified.
๐๐ฟ๐ฒ๐ฎ๐๐ฒ๐ฟ ๐๐๐ฝ๐ฝ๐น๐ ๐ฐ๐ต๐ฎ๐ถ๐ป ๐๐ถ๐๐ถ๐ฏ๐ถ๐น๐ถ๐๐: Businesses will need a fuller picture of who their suppliers are, where goods are sourced and what human rights risks may sit within those chains. Where visibility is poor, problems are harder to detect, especially when a product passes through several suppliers and stages of production.
๐ฆ๐๐ฟ๐ผ๐ป๐ด๐ฒ๐ฟ ๐๐๐ฝ๐ฝ๐น๐ถ๐ฒ๐ฟ ๐ผ๐๐ฒ๐ฟ๐๐ถ๐ด๐ต๐: Companies may have to revisit the way they evaluate suppliers, track labour practices and deal with concerns about forced labour. Having supplier policies in place is unlikely to be enough unless it is backed by proper checks and follow-up.
๐๐ป๐ฐ๐ฟ๐ฒ๐ฎ๐๐ฒ๐ฑ ๐ฎ๐ฐ๐ฐ๐ผ๐๐ป๐๐ฎ๐ฏ๐ถ๐น๐ถ๐๐: Businesses will be expected to take meaningful steps to address risks rather than relying solely on voluntary disclosures and reporting. This places greater emphasis on practical action and responsible supply chain management.
๐ฃ๐ผ๐๐ฒ๐ป๐๐ถ๐ฎ๐น ๐บ๐ฎ๐ฟ๐ธ๐ฒ๐ ๐ฟ๐ฒ๐๐๐ฟ๐ถ๐ฐ๐๐ถ๐ผ๐ป๐: The proposed law could allow authorities to remove products linked to forced labour from the Great Britain market, where certain conditions are met. This could lead to financial losses and other risks for businesses that fail to identify and address forced labour risks in their supply chains.
Even though the law will target only the biggest companies, the impact may filter down to smaller suppliers. Those companies may face stricter vetting from their larger customers, along with more frequent requests for information on how labour is managed across the supply chain.
While the final requirements are still being developed, businesses can begin reviewing their existing practices to identify gaps and prepare for potential changes.
Taking these steps can help businesses strengthen responsible sourcing practices and prepare for changing regulatory expectations.
Cognitud works with businesses on sustainability and responsible sourcing. Its focus is on supply chain risk: finding where it sits, tightening the way suppliers are vetted and making sure human rights are considered when sourcing decisions are made. Many organisations discover that they know less about their suppliers than they assumed, and that is often where the gaps in their existing processes become visible. As regulatory expectations evolve, Cognitud can support businesses in assessing their current practices and preparing for emerging supply chain requirements. By taking a proactive approach to risk management and responsible sourcing, businesses can build more transparent, resilient and accountable supply chains.
