Proposed legislation would require large businesses to identify and address human rights risks in their supply chains, while giving regulators powers to withdraw goods linked to forced labour from the Great Britain market.
The UK Government plans to introduce mandatory human rights due diligence requirements for large businesses, including retailers, in an effort to tackle forced labour and exploitation across global supply chains.
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The proposed rules would apply to UK businesses with annual global turnover exceeding £350 million, as well as overseas companies generating more than £350 million in annual UK turnover.
Announced on 4 November 2026 following a review of the UK’s Responsible Business Conduct (RBC) framework, the measures would require businesses to identify, assess and address human rights risks across their operations and supply chains.
The proposals would also give regulators powers to investigate suspected cases of forced labour involving goods sold in Great Britain and order their withdrawal under specified conditions.
For retailers and international brands operating in the UK, the changes could bring greater scrutiny of sourcing practices, supplier relationships and supply chain management.
UK sets out mandatory supply chain checks
Under the proposed legislation, mandatory human rights due diligence would apply to services across the UK and goods in Great Britain, covering England, Scotland and Wales.
Businesses within scope would have to identify potential human rights abuses and labour exploitation, assess the risks and take appropriate action to address them.
The Government said the framework would adopt a proportionate, risk-based approach aligned with international standards, including the Organisation for Economic Co-operation and Development (OECD) Guidelines for Responsible Business Conduct and the United Nations Guiding Principles on Business and Human Rights.
The proposals follow a government review that found the UK’s existing approach to tackling forced labour was fragmented and relied too heavily on voluntary measures and corporate reporting.
The review also concluded that the Modern Slavery Act 2015, regarded as a leading framework when introduced, had fallen behind developments in international standards and legislation among major trading partners.
The new requirements would focus on larger businesses with the resources and influence to address human rights risks within their supply chains.
Regulators to gain powers over forced labour goods
The proposed legislation would give regulators powers to investigate businesses suspected of placing goods produced using forced labour on the Great Britain market.
Where forced labour is identified and a business has failed to meet its due diligence obligations, regulators could order the withdrawal of affected products.
The Government said the measure was intended to protect workers and consumers while preventing businesses using exploitative labour practices from gaining an unfair competitive advantage.
Separate arrangements will apply in Northern Ireland, where the European Union’s Forced Labour Regulation will apply under the Windsor Framework, which governs aspects of the region’s post-Brexit trading arrangements.
The Government said the approaches in Great Britain and Northern Ireland were intended to achieve similar outcomes by allowing goods produced using forced labour to be withdrawn from their respective markets.
Retailers welcome proposals but raise concerns
The British Retail Consortium (BRC), which represents UK retailers, has welcomed the commitment to mandatory human rights due diligence but raised concerns about the exclusion of environmental requirements and the proposed turnover threshold.
Tom Ironside, the BRC’s director of policy, said: “The BRC and our members have long called for mandatory human rights and environmental due diligence, and we welcome the Government’s commitment to introduce a mandatory human rights due diligence regime.”
He said a risk-based approach aligned with international standards and supported by clear guidance could strengthen supply chain protections and establish more consistent requirements for businesses.
The BRC also welcomed confirmation that the EU Forced Labour Regulation would apply in Northern Ireland.
However, Ironside questioned the omission of environmental due diligence and the proposed £350 million turnover threshold.
“We are disappointed that environmental due diligence has been omitted, and the proposed £350 million turnover threshold needs careful consideration to ensure consistent obligations for all businesses exposed to similar risks,” he said.
The trade body called for close cooperation between the Government and industry to develop practical requirements that provide regulatory certainty while strengthening protections for workers across international supply chains.
Environmental due diligence left out
Although the Government’s RBC review considered both human rights and environmental due diligence, the proposed legislation focuses on human rights abuses and labour exploitation.
Environmental due diligence is therefore excluded from the mandatory regime as currently outlined.
The distinction matters for retailers with complex international sourcing networks, where supply chain risks can extend beyond labour conditions to environmental impacts.
The BRC also questioned whether the £350 million turnover threshold would ensure consistent treatment of businesses exposed to similar supply chain risks.
The Government has yet to indicate whether it will pursue separate mandatory environmental due diligence requirements.
What the proposals mean for retailers
If enacted, the legislation could require large retailers and international brands operating in the UK to strengthen how they identify, assess and manage human rights risks across their supply chains.
This could involve closer scrutiny of suppliers, greater transparency over sourcing arrangements and stronger procedures for identifying and addressing suspected labour exploitation.
Retailers sourcing products from multiple countries may also need to review their existing due diligence processes against the proposed UK requirements and relevant international standards.
However, the detailed compliance obligations, regulatory procedures and enforcement arrangements have yet to be established.
Alongside the legislation, the Government plans to establish a centralised responsible business conduct guidance hub on GOV.UK. It will bring together practical guidance, tools and templates to help businesses develop and implement due diligence processes.
The Government said it would work with stakeholders on the design and implementation of the measures, with legislation to be introduced as soon as parliamentary time allows. No implementation date has been confirmed.
For retailers, the next stage of policy development will clarify the scope of the new obligations, how businesses must address supply chain risks and what they will need to demonstrate to meet the requirements.
