The UK is on the verge of a major shift in how it tackles forced labour and human rights abuses in global value chains. Last month, the Independent Anti-Slavery Commissioner published a model legislative proposal aimed at strengthening the UK’s approach beyond the current Modern Slavery Act framework.
The proposal follows growing political and institutional pressure to move beyond the UK’s current transparency-based approach. In early 2025, the Business and Trade Select Committee signalled growing concern about forced-labour risks and the need for stronger supply-chain accountability, and later in 2025 the Joint Committee on Human Rights formally recommended mandatory human rights due diligence. Against this backdrop, the Independent Anti-Slavery Commissioner has now published model legislation setting out how a mandatory regime could work in practice.
What does the proposal involve, how would it work in practice, what are the key risks and, what should businesses be doing now?
What the proposal would do
1. Mandatory human rights due diligence
At the heart of the proposal is a requirement for companies to conduct mandatory human rights due diligence (MHRDD) across their operations and supply chains. This moves well beyond the current Modern Slavery Act’s reporting obligations, which are largely voluntary and focused on transparency rather than prevention.
Under the proposal, a company could be held responsible if a “serious human rights harm” occurs and the company:
- Caused it
- Contributed to it
- Was directly linked to it through its business relationships
Liability would not be automatic. A company would have a defence if it could demonstrate that it had carried out reasonable human rights due diligence to identify, prevent and address the risk. Where it cannot do so, it would face legal consequences, with the model law providing for both civil and criminal liability in certain cases.
This approach mirrors the UK’s established “failure to prevent” framework, under which organisations are held accountable not because harm occurred, but because they failed to put adequate preventive measures in place. Similar models already exist under the Bribery Act and the Economic Crime and Corporate Transparency Act, and the proposal applies that logic to human rights risk within corporate governance.
2. Forced labour import and export ban
A central feature would be a ban on importing, exporting or making available in the UK market goods made with forced labour. Unlike the current approach under the Modern Slavery Act or other import controls, the proposed ban would also cover transport and logistics services where forced labour can occur.
This mirrors global trends. The EU, for example, is introducing a forced labour regulation that will ban products made with forced labour from its market.
3. New oversight and transparency mechanisms
The proposal would establish:
- A new Office for Responsible Business Conduct within the Department for Business and Trade to monitor and enforce compliance
- A public registry of annual human rights statements, replacing the current Modern Slavery Statement regime to improve transparency and accountability
Ministers would be required to ensure that all UK legislation aligns with obligations to prevent business-related human rights impacts.
Why this matters now
A voluntary reporting approach has increasingly been viewed as insufficient. Reviews by parliamentary committees, legal commentators and civil society groups have highlighted that many Modern Slavery Act statements lack substance and have failed to drive meaningful change in business behaviour. At the same time, other jurisdictions are moving towards mandatory human rights due diligence, raising concerns that the UK risks falling behind international peers.
The Independent Anti-Slavery Commissioner’s proposal responds directly to these criticisms and to wider international developments. It is designed to bring UK law closer into line with global standards such as the UN Guiding Principles on Business and Human Rights and the OECD due diligence guidelines, which focus on identifying, preventing, mitigating and remedying human rights harm on a risk-based basis.
Supporters of the model law argue that this shift is essential to close enforcement gaps in the current regime and, critically, to improve access to remedy for workers affected by forced labour and other serious abuses.
The practical risks and questions
While the proposal is substantive, several practical concerns have been raised, especially around enforcement and resourcing.
Enforcement capacity
A core question is who actually enforces the law and how effectively. The proposal places oversight with the Office for Responsible Business Conduct, but:
- Resourcing for new enforcement bodies is uncertain
- Many government departments already face capacity constraints
- Effective enforcement would require strong coordination between customs authorities, regulators and prosecutors
Without clear funding and powers, enforcement could be slow or reactive, leaving companies unclear about expectations.
Supply chain complexity
Global value chains are large and opaque. Even sophisticated companies can struggle to map risks beyond first-tier suppliers. Mandating due diligence raises the bar, but practical implementation will require technical tools, risk-based prioritisation and credible evidence of actions taken.
Integration with other regimes
If the UK moves ahead with MHRDD alongside the EU’s emerging corporate due diligence laws, companies operating internationally will face overlapping requirements. That increases compliance complexity but also underscores the value of harmonising approaches where possible.
Why enforcement may still work
There are reasons to think enforcement could be effective despite these challenges:
- Focus on prevention: The law is structured to encourage companies to invest in due diligence systems, rather than waiting for government inspections.
- Familiar liability model: The “failure to prevent” framework is well-understood in UK corporate law, reducing uncertainty about legal tests.
- Targeted action: Enforcement is likely to prioritise high-risk sectors and evidence-led investigations, which is more practical than blanket compliance checks.
This design reflects lessons from other UK regulatory regimes where risk-based enforcement has driven change without excessive administrative burden.
What businesses should do now
Even though this proposal is not yet law, the direction of travel is clear. Businesses that take steps now will have a head start.
1. Embed human rights due diligence
Invest in risk mapping, supplier engagement and corrective action plans that align with:
These frameworks are likely to form the backbone of any future legal obligations.
2. Build capability
Develop internal expertise on human rights risks and supply chain due diligence, including training, data systems and escalation pathways.
3. Engage constructively
Participate in consultations and stakeholder dialogues to shape the final form of the law. Many companies are already hearing from the Independent Anti-Slavery Commissioner’s office as part of early engagement.
4. Align with global requirements
Prepare for overlapping international obligations by monitoring developments in the EU, US and other jurisdictions.
The UK’s proposed business and human rights law marks a shift from voluntary reporting to preventive accountability. It responds to long-standing concerns about forced labour and weak enforcement under the Modern Slavery Act, and reflects a broader global trend towards mandatory due diligence.
For businesses, this means moving beyond compliance as a reporting exercise towards proactive risk management, supplier engagement and genuine human rights accountability.
Modern slavery training helps your company or firm avoid being connected to activity that violates regulations, either directly or by proxy through supplier relationships. With a range of options, VinciWorks’ modern slavery training suite is designed to meet the needs of an entire team, from general staff to procurement teams.
Try it today.
