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techUK welcomes UK mandatory human rights due diligence legislation

10 November 20263 min read
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techUK welcomes UK mandatory human rights due diligence legislation

On 4 November, the Department for Business, Innovation, Science and Trade (BIST) published a ministerial statement confirming that it intends to introduce legislation to create a mandatory human rights due diligence (mHRDD) regime. Applying to businesses with a minimum £350m UK turnover, this will affect many businesses, including many techUK members.  

Why is government doing this? 

The UK was the first country in the world to introduce a mandatory disclosure-based transparency regime with Section 54 of the Modern Slavery Act (2015). However, in recent years, many other countries have introduced stronger legislation requiring companies not just report on their supply chain risks, but take action to address these, per international agreements including the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises ("the Guidelines"). 

Notably, the European Union recently passed the Corporate Sustainability Due Diligence Directive (CSDDD), which holds large companies legally accountable for human rights and environmental impacts across their own operations, subsidiaries, and global value chains, including companies based abroad that have a presence in the EU. Given the lower proposed turnover threshold in the UK, businesses may be in scope of the UK regime even if they are out of scope for CSDDD. Additionally, the EU Forced Labour Regulation (FLR) bans the sale, import, and export of products made with forced labour across the EU.  

Businesses, trade associations (including techUK), politicians and civil society groups have been calling on the UK government to introduce its own mandatory due diligence legislation to bring the country's legal standards on par with other jurisdictions. Due diligence helps businesses minimise their exposure to commercial risk, improve transparency and trust with customers, and provides the legal basis to demand better standards from suppliers.  

Domestic mHRDD legislation creates a level playing field by preventing companies with unethical practices undercutting more responsible businesses and prevents the UK becoming a "dumping ground" for goods made with forced labour. As such, some organisations have expressed disappointment that the UK regime does not mention any form of environmental due diligence. 

The new legislation: what we know so far 

This new due diligence regime will require companies to identify, assess and address human rights and labour risks within their operations and supply chains, with the broader aim to strengthen competitiveness. 

A few points to note: 

  • Applies to large UK businesses with a £350 million turnover, and overseas businesses with a £350 million UK turnover.  

  • Applies across the UK for services, and in Great Britain for goods (the EU's Forced Labour Regulation applies in Northern Ireland).  

  • "A regulator" will have the power to both investigate instances of goods made with forced labour being placed on the GB market, and direct their withdrawal.  

  • Government will establish a centralised RBC guidance hub on GOV.UK with guidance, tools and templates for companies.  

The Responsible Business Conduct (RBC) review  

In the 2025 Trade Strategy, the government confirmed it would: 

  • launch a review of our approach to responsible business conduct, focusing on the global supply chains of businesses operating in the UK 

This was conducted to consider the effectiveness of the UK's existing measures to get businesses to prevent and address human rights harms (such as forced labour) in their supply chains. Although not yet published (as of November 2026), the government has concluded that the UK's current framework for preventing forced labour is inadequate, in that it is fragmented across multiple pieces of regulation and overly reliant on voluntary action and reporting measures.  

The RBC review predated the recent imposition of tariffs, which followed claims that the UK was not doing enough on forced labour, but this announcement falls within the context of pressure across major economies to stop and prevent harms in global supply chains. 

Other regulations and ongoing changes 

Below is an overview of existing and emerging laws and regulations which include due diligence requirements:   

  • Immigration and Asylum Bill | includes an amendment which will strengthen section 54 of the MSA, including making the content of statements more prescriptive, requiring disclosures on risk assessment, policies, due diligence processes, training and effectiveness, and introducing a new financial penalties regime for non-compliance. 

  • The statement acknowledges that the IAB updates is an "important step", but more needs to be done.  

  • UK Forest Risk Commodities (FRC) regulation | per the Environment Act (2021), the UK will be consulting on regulations to ban illegal deforestation in supply chains to align with the EU Deforestation Regulation (EUDR).  

  • UK batteries consultation | government intends to consult on an EU-aligned batteries regime; the EU Batteries Regulation (EUBR) has specific provisions regarding due diligence.  

  • GB Energy Act | includes specific statutory provisions requiring human rights due diligence, particularly concerning imports and supply chains for solar and clean energy infrastructure.  

  • UK Procurement Act | requires procurers to conduct due diligence on suppliers.   

  • Health and Social Care Act | bans products made with forced labour going into the NHS.  

It will be interesting to see how government approaches introducing one overarching law which interacts with other regimes.   

Timelines and next steps 

Government has not indicated any specific timelines, only "when parliamentary time allows." We note that the EUFLR will take effect in NI December 2027 and the CSDDD from July 2029; therefore, it is possible NI will have a separate regime in place long before the rest of the GB market.  

techUK will be engaging with government and members on this issue throughout the process, including informational sessions, legislative analysis, and support with compliance.  

We are interested to hear what members think of this new announcement, and any questions you have, so please get in touch with Elisabeth or Craig to discuss further. If of interest, we will be discussing this at our next Responsible Business Conduct working group meeting, which members are welcome to attend.