Three UK Business & Human Rights Regulations that are Gaining Momentum in 2026

This blog was originally posted on 14th July, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY HANNAH JANKNECHT, SENIOR REGULATORY COMPLIANCE SPECIALIST & CRISTIAN BARROSO, REGULATORY COMPLIANCE SPECIALIST, ADHERENT

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Table of Contents

• Introduction
• Proposed Changes to the UK Modern Slavery Act
• UK Member’s Bill on Human Rights Due Diligence
• Upcoming Deforestation Regulation in the UK
• Conclusion

Introduction

Regulatory developments in the UK signal a shift towards more stringent laws and enforcement measures focused on supply chain due diligence and transparency. Recent initiatives, including a government Bill to revise the Modern Slavery Act 2015, a Private Member’s Bill proposing mandatory human rights due diligence, and the expected deforestation due diligence framework, reflect the UK’s growing momentum to strengthen its corporate accountability framework. This blog provides a snapshot of these key developments and examines potential implications for businesses operating in the UK.

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Proposed Changes to the UK Modern Slavery Act

Although the UK Modern Slavery Act was celebrated as a groundbreaking piece of legislation when it was introduced in 2015, it has since been outpaced by other global developments in the business and human rights space, including the EU Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Ban on Products made with Forced Labor (EUFL). 

A report issued by the UK Joint Committee on Human Rights in July 2025 found that the act in its current form is not suited to prevent goods linked to forced labour from entering the UK market. The committee recommended the introduction of mandatory due diligence, an import ban on goods linked to forced labour and the creation of civil liability for companies who do not take adequate steps to prevent forced labour in their supply chains. 

On 30 June 2026, the UK Home Office proposed a Bill to amend the Modern Slavery Act. Taking into account the previous criticism of the Act, it might come as a surprise that the Bill proposes neither mandatory due diligence nor the introduction of an import ban. Instead, the proposal maintains the transparency-focused approach by extending the content of the existing modern slavery statements. 

Scope

The criteria that bring companies into the scope of the obligation to publish a modern slavery statement remain unchanged. In scope are companies that

• Carry on a business, or part of a business, in the UK
• Supply goods or services, and
• Have an annual turnover of £36 million or more.

The Bill however proposes to extend the reporting obligations to certain public authorities. 

New Mandatory Content

Under the proposed amendment, companies in scope of the reporting obligations will have to include the information set out in the new schedule 4ZA:

• Information about the company’s structure, operations, and supply chains
• Risk Identification Information: The statement must satisfy one of three criteria regarding operational risk:
  • Specify the exact parts of its operations and supply chains where a risk of modern slavery exists (so far as reasonably available), alongside the steps taken during the financial year to assess, reduce, or remove that risk.
  • Explicitly state that there are no parts of its operations and supply chains where such a risk exists, detailing the steps taken to assess this.
  • Explicitly state that the company has not carried out an assessment of these risks during the financial year, providing the exact reasons why.
• Information about the modern slavery policies the company had in place during the financial year (or an explicit statement and reasons explaining why no such policies exist).
• Information about the due diligence processes implemented during the financial year within its operations and supply chains (or an explicit statement and reasons explaining why none were implemented).
• A specification of the modern slavery training made available to its own staff during the financial year (or a statement and reasons explaining why none was provided).
• A specification of training available to its own staff of its supply chains, a statement that no such training was made available, or a statement that the company did not make enquiries into supply chain training, accompanied by reasons.
• An assessment of the company’s effectiveness in ensuring modern slavery is not taking place, measured against its chosen performance indicators (or an explicit statement and reasons explaining why no steps or assessments were undertaken).

Publication

Companies must publish their modern slavery statement on their website, if they have one, and electronically submit the statement to the Secretary of State. Both should be completed as soon as reasonably practicable within six months following the end of the financial year. 

Penalties

The Modern Slavery Act in its current form has been criticized for its weak enforcement model, since only courts are able to issue fines, while authorities have to rely on injunctions. The proposed amendment changes this by giving the Secretary of State the ability to issue financial penalties. Excluding interest, the fine cannot exceed the higher of 1% of the organization’s total turnover or £1 million. Before issuing a penalty, a warning notice must be issued first.

Interested in finding out more about forced labour? Check out our blog ‘Football and Forced Labour: Why Supply Chain Due Diligence Is Essential‘

UK Member’s Bill on Human Rights Due Diligence

In addition to the developments outlined above, on 17 June 2026 a Private Member’s Bill on Human Rights and Environmental Due Diligence was introduced in the UK Parliament.

Due Diligence Requirements

The Bill would introduce a duty on UK commercial organisations to undertake human rights and environmental due diligence across their operations, subsidiaries and supply chains, aligned with international standards. As a minimum, organisations would be required to:

• Engage meaningfully with stakeholders;
• Embed gender-responsive due diligence into their policies and management systems;
• Identify, assess and address human rights, environmental and climate change risks;
• Establish effective grievance mechanisms;
• Monitor, assess and review the effectiveness of measures taken to address identified harms; and
• Communicate the outcomes of their due diligence activities.

The scope and complexity of “reasonable” due diligence will depend on the specific circumstances of each organisation, including its size, structure, operational context, position within the supply chain, and the nature of its products and services. It also makes clear that reliance solely on audit reports, certification schemes or industry memberships will not, in itself, be sufficient to satisfy the due diligence obligation.

A notable feature of the Bill is its approach to responsible disengagement. It provides that commercial organisations should suspend or terminate business relationships based on  “reasonable” due diligence and as a last resort. Disengagement should occur promptly where severe harm has been identified and continued engagement is not capable of preventing, mitigating or remedying that harm 

The Bill makes it clear that disengagement does not relieve commercial organisations of their obligation to remediate any harm they have caused or contributed. 

The Bill is intended to apply to the following commercial organisations:

• UK‑incorporated companies and UK‑formed partnerships carrying on business anywhere in the world; and
• Foreign companies or partnerships that carry on part of their business in the UK.

Reporting Obligations 

In addition to the due diligence obligations, the bill also establishes reporting and transparency requirements for companies with an annual turnover of £36 million or more. 

In particular, commercial organisations in scope would be required to file a verified due diligence report within six months of the end of each financial year that includes:

• Information on the organisation’s due diligence processes for identifying, preventing, mitigating and remediating actual and potential human rights and environmental impacts;
• A description of rightsholder engagement processes;
• Information on accessible local grievance mechanisms;
• Details of remediation provided or achieved;
• Reporting on Scope 1, Scope 2 and Scope 3 greenhouse gas emissions; and
• Information demonstrating alignment with the UN Guiding Principles on Business and Human Rights.

Similarly, organisations would disclose information regarding their ownership structures and value chain, including geolocation, enabling end-to-end traceability of goods and services, as well as on human rights and environmental harms grievances and remedy status. 

Civil Liability and Penalties

The Bill also introduces a civil liability regime for commercial organisations that fail to undertake reasonable human rights and environmental due diligence. Where a failure to comply results in harm, courts would have the power to award a range of remedies, including monetary damages and injunctive relief.

In addition, directors and partners may be held personally liable for a commercial organisation’s non-compliance, with potential sanctions including fines and imprisonment.

Finally, the Bill provides for fines to commercial organisations of up to 10% of their global turnover and exclusion from participation in public procurement procedures.

Upcoming Deforestation Regulation in the UK

While a mandatory due diligence framework for timber and timber products has been in place across the UK since 2013, successive UK governments have been working on a broader Deforestation Regulation for years.

In 2021, the UK adopted the new Environmental Act 2021. Schedule 17 of the Act sets out requirements for the ‘Use of Forest Commodities in Commercial Activities’. The schedule prohibits the use of forest risk commodities, unless they have been produced in compliance with relevant local laws. Companies using forest risk commodities or derived products are furthermore required to establish and implement a due diligence system to ensure compliance. In addition, companies must provide the authority with an annual report on the due diligence actions they have undertaken. 

Schedule 17 as the primary legislation has been in force since 30 September 2022, but in order to take effect, the UK government has to adopt implementing regulations setting out the missing details. 

Questions that need to be answered in the implementing regulations are:

• Which companies are subject to forest product due diligence? 
• Will there be exemptions based on weight and volume?
• Which specific commodities fall within the scope of these obligations? 
• What data must companies gather regarding their commodities and products?
• What criteria will be used to assess risks, and how can companies mitigate them?
• What information must be included in the annual report?

In a Policy Paper published on 23 June 2026 and titled ‘The UK’s approach to deforestation regulations’, the government has now provided first insights into some of these questions. 

Covered Commodities: The UK intends to cover the same core commodities as the EU Deforestation Regulation (EUDR) (EU) 2023/1115: wood, cattle, cocoa, coffee, palm oil, rubber, and soy. 

Derived Products: A number of yet-to-be-fully-defined derived products, such as chocolate and furniture, will also be subject to due diligence. 

Threshold: Unlike the EUDR, the UK framework will have an applicability threshold, which means only businesses with an annual turnover exceeding £1 million will be in scope.  

Data gathering: The information that companies will have to gather under the UK regulation will broadly be the same as that set out in the EUDR. 

Timeline: The government expects to deliver the regulation in 2027. 

In addition, the paper confirms the applicability of the EUDR in Northern Ireland, which means that UK businesses placing relevant commodities or products on the market in Northern Ireland will have to comply with the EUDR from 30 December 2026 (or 30 June 2027 respectively for small and micro enterprises). For further requests, the UK’s Office for Product Safety and Standards (OPSS) will act as the competent authority for rubber and wood products, and the Northern Irish Department of Agriculture, Environment and Rural Affairs ( DAERA) will act as the competent authority for palm oil, soy, cocoa, cattle and coffee.

Conclusion

Taken together, these developments signal a significant shift towards a stronger corporate responsibility framework in the UK, placing more pressure on businesses to implement robust due diligence and transparency measures to ensure that their products and supply chains are free from human rights and environmental harms.

As these proposals progress, the regulatory landscape for ethical supply chains is likely to remain dynamic, making this a critical area for monitoring and assessing their potential impact on companies’ obligations.

Want a concise, country-by-country overview of CSDDD implementation? Download the Adherent CSDDD Implementation Tracker.

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