On 4 November 2026, the UK Government confirmed plans to introduce a mandatory human rights due diligence regime for large businesses. The regime will apply to UK businesses with global turnover above £350 million and non-UK businesses generating more than £350 million in UK turnover.
The announcement was made in a written ministerial statement following the Government’s review of the UK’s approach to Responsible Business Conduct, as well as lobbying calls from businesses and industry groups for mandatory human rights and environmental due diligence legislation. This follows a recent Government Committee Report Response which noted the urgency of the Government’s review in light of new US tariffs connected with forced labour.
The key features announced so far are as follows:
- Due diligence: In-scope businesses will be required to identify, assess and address human rights and labour exploitation risks in their operations and supply chains;
- Territorial scope: The regime will cover services across the UK, and goods placed on the market in Great Britain, with the regulator given powers to remove goods made using forced labour from the Great Britain market. The EU Forced Labour Regulation will apply separately in Northern Ireland, however both regimes aim to deliver a similar effect in practice;
- Risk-based approach: The requirements will be aligned with the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights, meaning businesses already preparing for supply-chain due diligence requirements should have a useful starting point; and
- Guidance Hub: A centralised Responsible Business Conduct guidance hub is set to be established on the UK Government website, bringing together guidance, tools and templates in a single location.
The draft legislation and implementation timetable remain unclear. However, confirmation of the proposed thresholds means potentially in-scope businesses can begin assessing their exposure now. Existing supply-chain mapping, risk assessments and due-diligence processes developed for other regimes such as the EU Corporate Sustainability Due Diligence Directive or EU Forced Labour Regulation are likely to provide a useful foundation, although businesses will need to assess any differences once the UK legislation is published.
