On 4 November 2026, the UK Government announced plans to legislate for mandatory corporate human rights due diligence ("mHRDD") in response to its review of the UK's responsible business conduct framework.

The proposed legislation signals a significant shift away from the UK's current framework for managing adverse human rights impacts linked to corporate activity. That framework relies largely on voluntary action by corporates, aligned with international standards such as the UN Guiding Principles on Business and Human Rights ("UNGPs"), alongside several reporting and disclosure obligations applicable to certain companies, including under the Companies Act 2006 and section 54 of the Modern Slavery Act 2015 ("MSA").

In its announcement, the Government acknowledges that, despite the UK's early adoption of the MSA to address modern slavery (in particular, its corporate reporting obligations), the UK is now out of step with several G7 partners and other major trading economies. It states that further action is needed, on a phased and proportionate basis, to tackle forced labour and exploitation in global supply chains.

The development follows longstanding calls for reform, which have recently focused on detailed proposals for mHRDD and forced labour bans:

• In a report issued in December 2025, the Independent Anti-Slavery Commissioner called for broader corporate accountability, forced labour controls and mHRDD, proposing legislation in the form of a model bill. See further, our blog post.
• In June 2026, the Commercial Organisations and Public Authorities Duty (Human Rights and Environment) Bill was introduced as a Private Member's Bill and is currently at its second reading in the House of Lords. The Bill proposes both mHRDD and mandatory environmental due diligence.

Calls for corporate obligations on these issues are increasingly driven by business. Several companies recently wrote to the Prime Minister making the case for a single, clear legislative standard on mHRDD – and  environmental due diligence – aligned with the UNGPs and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct ("OECD Guidelines").

Key proposals

The Government's Immigration and Asylum Bill was introduced in June 2026 and has passed its second reading in the House of Commons. The Bill proposes stronger reporting requirements under the MSA, including mandatory statement content, a signatory declaration of accuracy and financial penalties for non-compliance. See further, our blog post.

The Government's new commitment goes beyond reporting, requiring in-scope businesses to identify, assess and address risks of human rights abuses and labour exploitation in their operations and supply chains.

The proposed mandatory, risk-based regime would apply to UK businesses with global turnover exceeding £350 million and non-UK businesses with UK-generated turnover exceeding £350 million. It would cover services across the UK, and goods in Great Britain. The Government intends to legislate for a proportionate, risk-based approach aligned with the OECD Guidelines and the UNGPs.

The proposed regime would also include powers to remove goods made with forced labour from the market in Great Britain. A regulator would be able to investigate businesses suspected of placing such goods on the market and order their withdrawal where due diligence obligations have not been met and forced labour is identified. In Northern Ireland, the Government has confirmed that the EU Forced Labour Regulation, which regulates the availability and export of products made with forced labour from the EU market, will apply under the Windsor Framework. See further, our blog post.

A central GOV.UK guidance hub on responsible business is also planned, which will house practical guidance for businesses in developing or refining their human rights due diligence processes.

Notably, the focus of this current commitment is on human rights. The Government has not indicated that it would introduce mandatory environmental (or climate-related) due diligence. In this respect, the commitment differs from the sustainability reporting and due diligence regimes already in force in the EU under the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive. See further, our blog post.

What should businesses do now?

The Government's announcement states that these measures will be introduced " as soon as parliamentary time allow".  There are many significant issues that would need to be resolved in any mHRDD legislation; key details remain open. These include:

• The scope of human rights to fall within mHRDD and the extent of the due diligence required in the business and in supply chains (for example, whether both upstream and downstream will be included).
• The turnover calculations to determine applicability of the obligations.
• Whether there will be any penalties or civil liability consequences in respect of failures to comply with mHRDD.
• The identity of the regulator responsible for enforcing the forced labour ban.

It remains to be seen whether the Government's proposed legislation will include features from the proposals for mHRDD outlined above. However, the direction is clear: the Government intends to move beyond disclosure towards mandatory, risk-based human rights due diligence with a focus on larger businesses and practical action.

 In the meantime, businesses potentially in scope should consider taking preparatory steps now, including:

1. Monitor legislative developments: Businesses should monitor the legislative process.

2. Assess likely in scope: Businesses should consider likely coverage, subject to further detail on treatment of groups of companies and turnover calculations.  

3. Map existing human rights due diligence processes: Businesses should review their current governance and management of adverse human rights impacts, including processes in place to map, assess, prioritise, escalate, take action on, remediate where appropriate, record and report, such impacts.

4. Focus on forced labour: Businesses should assess exposure to possible forced labour in supply chains given the potential forced labour ban.