UK Mandates Corporate Due Diligence: A New Era for Supply Chain Accountability

A Landmark Shift in UK Corporate Accountability

The United Kingdom is poised to redefine corporate responsibility with the announcement of a new mandatory human rights due diligence (mHRDD) law. Unveiled on November 4, 2026, this landmark policy signals a decisive move away from the transparency-focused approach of the Modern Slavery Act 2015 towards a more robust, mandatory framework. This new legislation will require large companies to actively identify, prevent, and mitigate human rights abuses within their global supply chains, marking a new era of corporate accountability.

What’s Changing? From Reporting to Regulation

For years, the UK’s approach to tackling abuses like forced labor in supply chains has relied on the Modern Slavery Act, which primarily requires large companies to publish an annual statement on the steps they’ve taken. However, following a government review that deemed this voluntary approach inadequate, the UK is now introducing a law with real enforcement power.

The proposed legislation will empower a new regulator to not only investigate claims but, crucially, to order the withdrawal of goods from the Great Britain market if they are found to be produced with forced labor and the company has failed to meet its due diligence obligations. This introduces tangible consequences for non-compliance, a significant departure from previous policy.

Key Provisions of the New Law

The new mandatory human rights due diligence regime will have a broad scope. Here are the key details:

• Who It Affects: The law will apply to both UK and non-UK businesses with a UK-generated turnover exceeding £350 million.
• Enforcement Power: A new regulator will have the authority to remove goods from the Great Britain market if they are linked to forced labor and due diligence requirements are not met.
• Scope: The legislation will cover services across the entire UK and goods sold in Great Britain.
• Timeline: The government plans to introduce the legislation “as soon as parliamentary time allows,” with the measures expected to take effect no earlier than December 2027.

The UK in a Global Context

This move aligns the UK more closely with international trends, particularly with the European Union’s upcoming Corporate Sustainability Due Diligence Directive (CSDDD) and Forced Labour Regulation. The UK’s £350 million turnover threshold is notably lower than the EU’s CSDDD threshold (over €1.5 billion), suggesting the UK’s rules may capture a wider range of companies.

However, a key difference is the scope of due diligence. The EU directive integrates both human rights and environmental harms (mHREDD), while the UK’s initial proposal focuses primarily on human rights. This has led to calls from campaigners for the UK to adopt a similarly integrated approach.

Furthermore, businesses operating across the UK will need to navigate a dual system. The new UK law will apply to Great Britain, while Northern Ireland will fall under the EU’s Forced Labour Regulation due to the Windsor Framework.

Expert Insights and What Businesses Should Do Now

The announcement has been widely welcomed by human rights advocates. Craig Bradshaw, Business and Human Rights Manager at Anti-Slavery International, stated, “We welcome the government’s recognition that the current Modern Slavery Act’s supply chain transparency requirements are insufficient… Comprehensive, dedicated and robust legislation is essential.”

For businesses, the message is clear: preparation is key. The transition to a mandatory due diligence framework requires a proactive approach. Legal experts advise that companies should begin taking the following steps:

1. Review Existing Processes: Assess and strengthen current compliance and risk management systems related to human rights.
2. Map Supply Chains: Gain deeper visibility into every tier of your supply chain to identify potential risks.
3. Develop a Coordinated Strategy: Create a cross-border compliance strategy that accounts for the differing regulations in the UK and EU.

To aid in this transition, the government has announced plans to create a centralized responsible business conduct guidance hub on its GOV.UK website.

Conclusion: A New Standard for Corporate Responsibility

The UK’s upcoming mandatory due diligence law represents a fundamental change in how corporate Britain is expected to operate on the global stage. By moving from voluntary reporting to mandatory action with significant penalties, the government is setting a new, higher standard for supply chain accountability. While challenges remain, particularly regarding regulatory alignment with the EU and the inclusion of environmental harms, this legislation is a critical step toward ensuring that UK supply chains are free from forced labor and other human rights abuses. Businesses that act now to embed robust due diligence into their operations will be best positioned to thrive in this new regulatory landscape.