The UK is edging towards a major reset on business and human rights. After a House of Lords committee concluded in 2024 that the UK had “fallen behind” international peers, ministers used the 2025 Trade Strategy to promise a review of Responsible Business Conduct (RBC) and to “reaffirm” that UK businesses should conduct risk-based human rights and environmental due diligence.
But in July 2025, Parliament’s Joint Committee on Human Rights (JCHR) went further, recommending new legislation within a year to mandate due diligence across supply chains and to ban goods linked to forced labour from the UK market.
While the EU has been backtracking on human rights due diligence, the Labour Party have previously committed to strengthening the role of human rights in UK supply chains. As the government moves into its second year in power, the likelihood of new requirements on businesses is growing. The existing human rights framework under OECD rules has already snared UK firms like Chapman Taylor who are being investigated by the UK National Contact Point (NCP), a live example of the kind of corporate conduct that could fall squarely within a new UK law.
The international framework: from voluntary standards to hard law
For a decade, the UN Guiding Principles (UNGPs), OECD Guidelines and ILO instruments have defined the global baseline: companies should identify, prevent, mitigate and account for human-rights impacts, i.e., run human rights due diligence (HRDD), irrespective of where they operate. The UK’s Trade Strategy expressly anchors to these frameworks and tells businesses to conduct risk-based human rights due diligence.
Meanwhile, the legislative tide has turned in the UK’s main markets:
EU Forced Labour Regulation (FLR): directly bans products made with forced labour from 14 December 2027, with earlier milestones for appointing competent authorities and guidance.
CSDDD (EU): the EU’s due-diligence directive (despite its “Omnibus” simplification) pushes binding HRDD across value chains; the UK has already been discussing it with the EU in the TCA committees to manage cross-border frictions.
With the EU hardwiring human rights due diligence and market bans into law, it’s no surprise that the Joint Committee on human rights believes the UK is falling behind, and the potential for new legislative action has grown significantly.
The UK today: a patchwork that doesn’t keep tainted goods out
The UK’s existing human rights in supply chain rules are a messy mix of ageing statutes and soft-law guidance:
Modern Slavery Act 2015: transparency reporting for large companies; updated government guidance was issued in July 2025.
Bribery Act 2010, Procurement Act 2023, sectoral duties (e.g., Great British Energy Act 2025), and enforcement tools under POCA 2002.
OECD Guidelines via the UK NCP (now presented publicly under the Office for Responsible Business Conduct branding).
But the JCHR’s verdict in their report, backed by extensive evidence, is stark: the current framework does not prevent goods linked to forced labour entering the UK, and voluntary reporting under the Modern Slavery Act has not delivered consistent, meaningful action. It calls for mandatory HRDD, an import/sales ban for forced-labour goods, and a civil “duty to prevent” so victims can sue.
Taken together, these reforms would significantly impact broad sections of UK businesses, who would need to prove that their goods and services are not connected to human rights violations abroad. This would require far more extensive oversight over every tier of the supply chain, far deeper than many firms are currently able to deliver.
What are the proposals that the government is considering?
The report of Parliament’s Joint Committee on Human Rights (JCHR) is not binding, however it does increase the likelihood of new primary legislation. Nevertheless, the government is proceeding with various piecemeal human rights reviews.
Trade Strategy (July 2025): commits to reviewing the UK’s approach to RBC and “championing” international standards; it reaffirms expectations of risk-based HR/ENV due diligence across UK business.
Strengthening s.54 MSA: the JCHR records Home Office confirmation that the review includes options to tighten reporting requirements, revisit turnover thresholds, and add penalties.
UK NCP refresh: government pages now list case statements under the Office for Responsible Business Conduct banner—signalling an institutional refresh of the NCP’s role as the UK’s non-judicial grievance mechanism.
Despite these bits of progress, the JCHR makes a firm recommendation for legislative change. However there is no published draft bill yet on mandatory due diligence or an import ban. The next steps sit with ministers. If they decide to proceed, we would then see a public consultation laying out scope, model and thresholds for enforcement. If the government does decide to proceed, we would probably see a consultation of this sort launched in the 2026 King’s Speech.
Current human rights investigations: The Chapman Taylor case
While we wait on legislation, some human rights cases are already being brought through the current framework. In August 2025, the UK NCP accepted a complaint by Avan Shushi Partnership against UK architects Chapman Taylor LLP over alleged OECD Guidelines breaches linked to the post-conflict redevelopment of the town of Shushi in the conflict area of Nagorno-Karabakh in Azerbaijan.
The initial assessment finds the issues “material and substantiated,” moving the case to mediation and further examination. Allegations include failure to conduct risk-based due diligence, failure to use leverage to prevent or mitigate harms, and linkage to adverse human-rights impacts on displaced Armenians and cultural heritage.
While NCP enforcement is limited, this case does serve as a potential warning for all kinds of professional service businesses involved in conflict-affected regions.
- It shows professional services (not just manufacturers) are expected under OECD/UNGPs to do context-sensitive HRDD, especially in conflict-affected settings.
- It demonstrates how non-judicial mechanisms (NCP) can trigger serious reputational and commercial consequences, even absent binding sanctions.
- Under a future UK law, the same fact pattern could crystallise into statutory duties, potential civil liability, and procurement/market access consequences.
What future UK legislation could look like
Drawing on the JCHR’s detailed blueprint, practice in the EU/US, and the Trade Strategy’s framing, a UK human rights due diligence law would likely include the following elements.
Scope and thresholds
Risk-based, proportionate duties, with lighter requirements for SMEs but coverage based on risk exposure, not just turnover.
Likely staged commencement and sectoral focus (high-risk categories such as apparel, polysilicon/solar, seafood, critical minerals).
Core duties (UNGPs/OECD-aligned)
Identify and assess actual/potential impacts across own operations and value chains.
Prevent/mitigate and track effectiveness; use and build leverage; enable remediation; and publish targeted disclosures (beyond box-ticking TISC statements).
Board-level accountability and integration with risk, audit, and procurement.
Civil liability – a statutory “duty to prevent”
A private right of action for persons harmed by forced labour and related abuses, shifting the onus onto companies to show adequate due diligence which would be analogue to “adequate procedures” defences in Bribery Act terms
Market measures – import/sales ban
A UK-tailored ban on importing or selling goods linked to forced labour, likely modelled on the EU FLR, with attention to avoiding UFLPA-style reversals of burden that might create trade frictions.
Competent authority designation, investigatory powers, detention/seizure procedures, and penalties that are “effective, proportionate and dissuasive.”
Enforcement architecture
A strengthened Office for Responsible Business Conduct (evolved NCP) coordinating with Home Office, DBT, HMRC/Border Force, CMA and procurement authorities, plus a funded intelligence function (e.g., tracing high-risk inputs like polysilicon, cotton, seafood).
Public procurement hooks
Clear exclusion grounds and award criteria tying HRDD performance to eligibility for public contracts, aligned with the Procurement Act and sector policies (e.g., energy).
Trade policy coherence
Human- and labour-rights clauses in FTAs (with monitoring and impact assessment), so due-diligence norms are reinforced across trade relationships.
Business support and transition
Government toolkits, guidance (building on the July 2025 MSA guidance), approved industry schemes, and safe-harbour incentives for demonstrably effective HRDD.
What this would change in practice
For boards: HRDD becomes a standing enterprise risk with director-level oversight and KPI-tracked mitigation.
For legal/compliance: new defences will depend on the quality of due diligence (not presence of a policy).
For procurement/supply-chain teams: contractual leverage, traceability, grievance mechanisms, and remediation become non-negotiable.
For professional services: projects in conflict-affected or politically sensitive areas will require heightened HRDD; failing to assess cultural heritage/property risks (as alleged in Chapman Taylor) could become a statutory breach.
How should compliance teams prepare for possible human rights due diligence legislation?
While no legislation, or even a consultation, has yet been announced, the direction of travel is clear. From the Trade Strategy review to the NCP refresh and the JCHR recommendations, the push is towards mandatory, risk-based HRDD alongside a forced-labour market ban and a requirement to show adequate due diligence.
Firms, especially those with exposure to high risk conflict and post-conflict zones, should begin to understand how future legislation may affect them. Steps to begin taking now include:
- Map high-risk products and geographies
- Upgrade supplier onboarding and monitoring, including leverage strategies and exit protocols
- Implement operational-level grievance mechanisms
- Rehearse import-ban scenarios
- Align disclosures to go beyond Modern Slavery Act statements
