A decade after the Modern Slavery Act 2015 (MSA), the UK’s once-leading framework sits at a crossroads. The Independent Anti‑Slavery Commissioner’s recent report finds that the UK transparency-based model is now viewed as fragmented and operating without meaningful enforcement. Under the current regime, businesses can legally comply by submitting a statement saying they have taken no steps to address modern slavery, and the consequences for failing to publish a statement at all are minimal in practice.
As a result, the UK is now significantly outpaced by international developments. The report concludes that a full legislative refresh, centred on mandatory, enforceable human rights due diligence (HRDD) and stronger trade enforcement, is essential to protect workers and ensure responsible businesses are not undercut. For supply‑chain‑intensive businesses reliant on stable, resilient and ethically sound sourcing, this gap poses both operational and reputational risks.
The Independent Anti-Slavery Commissioner warns that without reforms aligned to global standards, the UK risks becoming “a dumping ground” for goods made with forced labour once the EU’s import ban takes effect. Leading businesses and investors share this concern. From major UK retailers to international consumer brands, the consensus is that robust, mandatory HRDD is critical to protect workers, safeguard the UK’s credibility and to protect UK supply chains from structural risk and reputational exposure.
Current state of play: Why the UK needs to strengthen its framework
Voluntary transparency is no longer enough. Section 54 of the MSA catalysed reporting, but it does not require companies to prevent harm, and penalties for poor or absent statements are weak. The result has been inconsistent quality and limited impact for exploited workers. In addition, fragmented domestic rules are adding cost and confusion. Sector‑specific legislation such as due‑diligence‑style obligations in NHS procurement and the Great British Energy Act 2025 has created duplication and conflicting expectations for supply chain operators trying to maintain coherent compliance systems across multiple regimes.
The scale and economics of harm are compelling. The UK faces significant recurring costs from modern slavery (estimated at around £60bn annually), while importing approximately £20bn of goods each year at risk of being produced through forced labour. With the EU’s forced‑labour product ban applying from 2027, the UK risks becoming an outlet for blocked goods unless it aligns its own regime. For supply chain leaders, this introduces a clear operational risk: diversion of non-compliant goods into the UK market could disrupt procurement, create customs delays, and expose businesses to unexpected enforcement.
A broad societal consensus supports change too. Survivors, businesses, investors and the public are all calling for mandatory, enforceable standards.
International developments – and how the UK is falling behind
Over the past decade, many of the UK’s major trading partners have moved from voluntary transparency to mandatory human rights due diligence (MHRDD) and enforceable import controls. The EU has led this shift through the Corporate Sustainability Due Diligence Directive (CSDDD), which from 2027 will impose binding HRDD duties and civil liability across global value chains, and the 2024 Forced Labour Regulation, which bans forced-labour-linked products from entering or leaving the EU. France, Germany and Norway have also enacted due diligence laws requiring structured risk assessment, stakeholder engagement, grievance mechanisms and meaningful sanctions.
Beyond Europe, the United States has tightened border enforcement through the Uyghur Forced Labor Prevention Act (UFLPA), which presumes goods from Xinjiang are made with forced labour unless proven otherwise. Canada, South Korea, Brazil, Thailand, Australia and New Zealand are likewise moving toward due-diligence-based regimes and stricter trade controls.
This global shift reflects a clear consensus: voluntary reporting does not prevent harm, and mandatory, enforceable due diligence is now the international norm. Without comparable reforms, the UK risks becoming an outlier, and potentially a “dumping ground” for goods barred from stronger jurisdictions, undermining responsible businesses and its credibility as an ethical trading partner. For supply chain executives, this means misalignment between regulatory regimes will increase operational complexity and create trade-flow friction unless the UK modernises.
What changes to the UK’s Forced Labour and Human Rights Legislative Framework is the Independent Anti-Slavery Commissioner proposing?
The Independent Anti-Slavery Commissioner’s draft Forced Labour and Human Rights Bill 2026 sets out wide-ranging reforms to bring the UK in line with international best practice. The rules would apply to large organisations with a global turnover of £36 million or more, whether UK-based or overseas but operating in the UK, as well as public undertakings engaged in commercial activity. Financial services providers are expressly included. SMEs fall outside direct regulation but will be affected as part of larger companies’ value chains.
Key proposals include:
- A statutory “failure to prevent” duty
Organisations would be legally liable where they cause, contribute to, or are directly linked to serious human rights harms anywhere in their value chain. This shifts the UK from voluntary transparency to mandatory accountability, mirroring the Bribery Act and aligning with global HRDD laws such as those in France, Germany and the CSDDD. Applying the duty to global operations reduces incentives to offshore exploitation and provides clearer expectations for supply chain oversight at every tier.
- A “reasonable human rights due diligence” defence
Companies may avoid liability by demonstrating reasonable, proportionate, risk-based due diligence consistent with the UNGPs and OECD Guidelines. This balances firm duties with flexibility, allowing expectations to scale by size, resources and risk, and encouraging continuous improvement rather than tick-box compliance.
- Strengthened civil enforcement
A new Office for Responsible Business Conduct would be able to issue public censures, compliance, compensation, costs and restoration notices, a penalty notice of up to 5% of global turnover, and exclusions from public procurement.
These sanctions introduce meaningful commercial consequences, reflecting EU-style enforcement and posing particular implications for public-contract-reliant sectors and for supply chain-heavy industries with complex multi-jurisdictional sourcing models.
Criminal liability for serious abuses
For offences such as slavery, trafficking, GBH or corporate manslaughter, both organisations and consenting/conniving senior officers could face criminal prosecution. This elevates human rights from a compliance issue to a criminal risk, driving greater board-level oversight.
- A UK-wide forced labour product ban
The Bill would ban the import, export and sale of goods made or transported with forced labour, including presumptive bans for high-risk regions or products and a public risk database. This aligns the UK with EU, US and Canadian regimes and closes a major gap in current law by stopping forced-labour goods at the border rather than merely requiring reporting. For supply‑chain leaders, this would materially alter customs screening, supplier onboarding, and product‑traceability expectations.
- A mandatory annual Human Rights Statement
In the place of the Modern Slavery Statement, a mandatory annual Human Rights Statement would create enforceable disclosure obligations. Organisations above the threshold would be required to publish a board-approved, evidence-based statement setting out any serious human rights harms for which they may be responsible; an explanation where no such harms are identified; a forward-looking plan for prevention and mitigation; and an assessment of the effectiveness of actions taken. The statement would be uploaded to a central public registry, and failure to comply could result in financial penalties, closing the long-criticised enforcement gap in the MSA. This shifts the current voluntary model into a substantive, outcome‑focused reporting requirement.
Next steps and timescales
The Independent Anti-Slavery Commissioner urges the Government to adopt the Bill in the next King’s Speech. The legislation is designed to come into force two years after enactment, giving organisations time to embed human rights due diligence. Within six months of commencement, the Office for Responsible Business Conduct must be fully operational, and within six months of passage the forced-labour database and enforcement regulations must be established. Guidance on reasonable due diligence and other key concepts must be issued within one year.
What should your business do?
Given the practical difficulties in achieving full supply‑chain visibility, together with the direction of travel indicated by key trading partners and the Independent Anti-Slavery Commissioner’s recent recommendations, there is value in forward‑looking businesses taking early steps to prepare for potential legislative change.
This should include measures such as mapping value chains beyond Tier 1 and identifying structural risks and visibility gaps, as well as investing in evidence systems for future human rights disclosures such as traceability tools. Reviewing trade compliance is especially vital for high-risk products and regions, and supply chain leaders should also consider strengthening governance structures and ensuring board-level oversight and integration into procurement processes. The value of fostering a culture which encourages employees to speak up should also not be overlooked.
Supply chain leaders who act early will be best positioned to manage risk, assure continuity and maintain competitive advantage.
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