The UK's due diligence law: what's been announced and what's still open

What's been announced

On 4 November 2026, Business and Trade Secretary Jonathan Reynolds set out the government's plans in a written statement to Parliament. They follow a review of the UK's approach to responsible business conduct, promised in the government's Trade Strategy. The review found the UK's framework for preventing forced labour to be "fragmented and overly reliant on voluntary action and reporting measures".

The government will legislate to introduce a mandatory human rights due diligence regime. It will apply to:

• UK businesses with a global turnover of over £350 million.
• Non-UK businesses with a UK-generated turnover of over £350 million.

Businesses in scope will have to identify, assess and address risks of human rights abuses and labour exploitation in their operations and supply chains. The regime will cover services across the UK and goods in Great Britain. The government says it will be risk-based and aligned with the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.

A regulator will be able to investigate businesses suspected of placing goods made with forced labour on the market in Great Britain. Where forced labour is identified and due diligence obligations have not been met, it will be able to direct the goods' withdrawal. In Northern Ireland, the EU Forced Labour Regulation will apply under the Windsor Framework.

The government also plans a guidance hub on GOV.UK with tools and templates, aimed particularly at businesses building due diligence processes for the first time.

What isn't known yet

This is just a commitment to legislate. There is no bill for the new regime yet, and the government will introduce the measures "as soon as parliamentary time allows". The statement does not name the regulator, set out penalties or say what businesses in scope will need to report.

It does say the government will work with stakeholders on design and implementation, and that requirements will prioritise action over unnecessary paperwork.

How it fits with the Modern Slavery Act changes

Section 54 of the Modern Slavery Act 2015 already requires businesses with a turnover of £36 million or more to publish an annual modern slavery statement. The Immigration and Asylum Bill, before Parliament as of November 2026, would change that duty. As introduced, the Bill would:

• Set out what a statement must contain, including where in operations and supply chains there is a risk of modern slavery and the steps taken to assess and reduce it.
• Require the person signing the statement to declare it accurate to the best of their knowledge and belief.
• Extend the duty to public authorities.
• Allow the government to introduce financial penalties of up to £1 million or 1% of turnover, whichever is higher, for failing to comply without reasonable excuse.

The Bill tightens reporting, while the new human rights due diligence regime would add a duty for the largest businesses to identify and address risks across the whole range of human rights, not just forced labour.

The international picture

The government says the UK has fallen "out-of-step with G7 partners and other major trading economies". In the EU, the Corporate Sustainability Due Diligence Directive, reshaped by Omnibus I, applies from July 2029, and the EU Forced Labour Regulation applies from 14 December 2027.

In the US, additional Section 301 tariffs have applied since July 2026 to imports from economies that the US says have not imposed and effectively enforced a ban on goods made with forced labour. The UK is among them, at the lower 10% rate.

Steve Gibbons, Global Head of Consulting at LRQA, says: "Two things are clear. First, there is a growing move towards mandatory human rights due diligence obligations for companies. Second, forced-labour controls are becoming a market access issue. Businesses with global supply chains will increasingly need to show the same evidence to the UK, the EU and the US on what they do and how their supply chains are managed."

What companies likely to be in scope can do now

The final requirements are not yet known. The government has said the regime will align with the OECD Guidelines and the UN Guiding Principles on Business and Human Rights, which already describe what due diligence involves. Businesses can use them as a reference now to:

• Map where in their own operations and supply chains people are most at risk.
• Check whether current processes go beyond identifying risks to addressing them, and whether that work can be evidenced.
• Review how their modern slavery statement would meet the new content requirements in the Immigration and Asylum Bill.

This article provides general information and does not constitute legal advice.