On 4 November 2026, the UK Government committed to legislate for mandatory human rights due diligence for businesses. The announcement follows the Government's review of its responsible business conduct framework. Here are five things to know about the proposed regime:
1. Proposed coverage of UK and non-UK businesses
- UK businesses with global turnover above £350 million
- Non-UK businesses with UK-generated turnover above £350 million
Businesses in scope would need to identify, assess and address risks of human rights abuses and labour exploitation in their operations and supply chains. The approach mirrors EU regimes' treatment of EU and non-EU businesses' turnover to promote a level playing field, but the proposed company-level UK thresholds are significantly lower than the €1.5bn threshold under the EU's Corporate Sustainability Due Diligence Directive (CSDDD). See our summary of the CSDDD here.
2. Risk-based due diligence aligned with international standards
The proposed regime is intended to be risk-based, proportionate and aligned with international standards, including the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights. The proposals address issues also covered by the CSDDD and Forced Labour Regulation (EUFLR), but should not be assumed to follow either model: the UK regime's detailed scope, duties and enforcement framework remain to be settled. In particular, the UK proposals do not address environmental harms. A UK regulator would be able to require goods to be withdrawn from the Great Britain market where due diligence obligations have not been met and forced labour is identified. The proposed regime would cover services across the UK and goods in Great Britain, i.e. the UK excluding Northern Ireland, where the EUFLR would apply from 14 December 2027, subject to its addition to the Windsor Framework and the applicable democratic scrutiny safeguards.
3. The policy commitment is clear, the timetable is not
The Government says it will introduce the measures “as soon as parliamentary time allows”, so establishing a policy direction but not a fixed legislative timetable. The accompanying explanatory memorandum envisages application of the proposed UK forced labour measures no earlier than December 2027, but does not confirm a commencement date. Key questions remain, including how turnover will be determined, the extent of due diligence required and the enforcement consequences. The Government intends to consult stakeholders on design and implementation.
4. Related reforms to modern slavery reporting and business guidance
Calls for reform, including through private members' bills and from the UK's Independent Anti-Slavery Commissioner, have focused on human rights due diligence and forced labour trade bans. In June 2026, the Government proposed strengthening the Modern Slavery Act through the Immigration and Asylum Bill, introducing mandatory content for reports, a declaration of accuracy and financial penalties for non-compliance. The Government also intends to establish a centralised responsible business conduct hub on GOV.UK, bringing guidance, tools and templates together in one place.
5. Steps businesses can take now
What should businesses do now? Take a coordinated, cross-border approach to human rights due diligence and forced labour compliance, rather than treating the UK proposals in isolation. Review how existing compliance work across relevant markets could support future UK-specific requirements, particularly supply chain risk mapping, traceability, due diligence, remediation and documentation. Use the OECD Guidelines and UN Guiding Principles as reference points, while allowing for differences between national regimes as the UK proposals develop.
White & Case means the international legal practice comprising White & Case LLP, a New York State registered limited liability partnership, White & Case LLP, a limited liability partnership incorporated under English law and all other affiliated partnerships, companies and entities.
This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.
© 2026 White & Case LLP
