The UK is on the verge of a serious shift in the way it tackles compelled labour and human rights abuses in world worth chains. Final month, the Impartial Anti-Slavery Commissioner revealed a mannequin legislative proposal geared toward strengthening the UK’s strategy past the present Trendy Slavery Act framework.
The proposal follows rising political and institutional stress to maneuver past the UK’s present transparency-based strategy. In early 2025, the Enterprise and Commerce Choose Committee signalled rising concern about forced-labour dangers and the necessity for stronger supply-chain accountability, and later in 2025 the Joint Committee on Human Rights formally beneficial obligatory human rights due diligence. Towards this backdrop, the Impartial Anti-Slavery Commissioner has now revealed mannequin laws setting out how a compulsory regime may work in apply.
What does the proposal contain, how wouldn’t it work in apply, what are the important thing dangers and, what ought to companies be doing now?
What the proposal would do
1. Obligatory human rights due diligence
On the coronary heart of the proposal is a requirement for firms to conduct obligatory human rights due diligence (MHRDD) throughout their operations and provide chains. This strikes effectively past the present Trendy Slavery Act’s reporting obligations, that are largely voluntary and centered on transparency fairly than prevention.
Beneath the proposal, an organization may very well be held accountable if a “severe human rights hurt” happens and the corporate:
- Brought about it
- Contributed to it
- Was straight linked to it by means of its enterprise relationships
Legal responsibility wouldn’t be automated. An organization would have a defence if it may show that it had carried out affordable human rights due diligence to determine, forestall and handle the danger. The place it can not accomplish that, it might face authorized penalties, with the mannequin legislation offering for each civil and felony legal responsibility in sure instances.
This strategy mirrors the UK’s established “failure to stop” framework, beneath which organisations are held accountable not as a result of hurt occurred, however as a result of they didn’t put enough preventive measures in place. Comparable fashions exist already beneath the Bribery Act and the Financial Crime and Company Transparency Act, and the proposal applies that logic to human rights danger inside company governance.
2. Compelled labour import and export ban
A central function could be a ban on importing, exporting or making accessible within the UK market items made with compelled labour. In contrast to the present strategy beneath the Trendy Slavery Act or different import controls, the proposed ban would additionally cowl transport and logistics providers the place compelled labour can happen.
This mirrors world tendencies. The EU, for instance, is introducing a compelled labour regulation that can ban merchandise made with compelled labour from its market.
3. New oversight and transparency mechanisms
The proposal would set up:
- A brand new Workplace for Accountable Enterprise Conduct inside the Division for Enterprise and Commerce to watch and implement compliance
- A public registry of annual human rights statements, changing the present Trendy Slavery Assertion regime to enhance transparency and accountability
Ministers could be required to make sure that all UK laws aligns with obligations to stop business-related human rights impacts.
Why this issues now
A voluntary reporting strategy has more and more been seen as inadequate. Evaluations by parliamentary committees, authorized commentators and civil society teams have highlighted that many Trendy Slavery Act statements lack substance and have didn’t drive significant change in enterprise behaviour. On the similar time, different jurisdictions are shifting in the direction of obligatory human rights due diligence, elevating considerations that the UK dangers falling behind worldwide friends.
The Impartial Anti-Slavery Commissioner’s proposal responds straight to those criticisms and to wider worldwide developments. It’s designed to carry UK legislation nearer into line with world requirements such because the UN Guiding Ideas on Enterprise and Human Rights and the OECD due diligence tips, which concentrate on figuring out, stopping, mitigating and remedying human rights hurt on a risk-based foundation.
Supporters of the mannequin legislation argue that this shift is crucial to shut enforcement gaps within the present regime and, critically, to enhance entry to treatment for staff affected by compelled labour and different severe abuses.
The sensible dangers and questions
Whereas the proposal is substantive, a number of sensible considerations have been raised, particularly round enforcement and resourcing.
Enforcement capability
A core query is who truly enforces the legislation and the way successfully. The proposal locations oversight with the Workplace for Accountable Enterprise Conduct, however:
- Resourcing for brand new enforcement our bodies is unsure
- Many authorities departments already face capability constraints
- Efficient enforcement would require sturdy coordination between customs authorities, regulators and prosecutors
With out clear funding and powers, enforcement may very well be gradual or reactive, leaving firms unclear about expectations.
Provide chain complexity
International worth chains are giant and opaque. Even refined firms can wrestle to map dangers past first-tier suppliers. Mandating due diligence raises the bar, however sensible implementation would require technical instruments, risk-based prioritisation and credible proof of actions taken.
Integration with different regimes
If the UK strikes forward with MHRDD alongside the EU’s rising company due diligence legal guidelines, firms working internationally will face overlapping necessities. That will increase compliance complexity but in addition underscores the worth of harmonising approaches the place doable.
Why enforcement should still work
There are causes to suppose enforcement may very well be efficient regardless of these challenges:
- Concentrate on prevention: The legislation is structured to encourage firms to spend money on due diligence techniques, fairly than ready for presidency inspections.
- Acquainted legal responsibility mannequin: The “failure to stop” framework is well-understood in UK company legislation, lowering uncertainty about authorized checks.
- Focused motion: Enforcement is prone to prioritise high-risk sectors and evidence-led investigations, which is extra sensible than blanket compliance checks.
This design displays classes from different UK regulatory regimes the place risk-based enforcement has pushed change with out extreme administrative burden.
What companies ought to do now
Regardless that this proposal is just not but legislation, the route of journey is evident. Companies that take steps now could have a head begin.
1. Embed human rights due diligence
Spend money on danger mapping, provider engagement and corrective motion plans that align with:
These frameworks are prone to type the spine of any future authorized obligations.
2. Construct functionality
Develop inner experience on human rights dangers and provide chain due diligence, together with coaching, information techniques and escalation pathways.
3. Interact constructively
Take part in consultations and stakeholder dialogues to form the ultimate type of the legislation. Many firms are already listening to from the Impartial Anti-Slavery Commissioner’s workplace as a part of early engagement.
4. Align with world necessities
Put together for overlapping worldwide obligations by monitoring developments within the EU, US and different jurisdictions.
The UK’s proposed enterprise and human rights legislation marks a shift from voluntary reporting to preventive accountability. It responds to long-standing considerations about compelled labour and weak enforcement beneath the Trendy Slavery Act, and displays a broader world development in the direction of obligatory due diligence.
For companies, this implies shifting past compliance as a reporting train in the direction of proactive danger administration, provider engagement and real human rights accountability.
Trendy slavery coaching helps your organization or agency keep away from being related to exercise that violates rules, both straight or by proxy by means of provider relationships. With a variety of choices, VinciWorks’ fashionable slavery coaching suite is designed to satisfy the wants of a complete group, from normal employees to procurement groups.
Strive it at this time.
The UK is on the verge of a serious shift in the way it tackles compelled labour and human rights abuses in world worth chains. Final month, the Impartial Anti-Slavery Commissioner revealed a mannequin legislative proposal geared toward strengthening the UK’s strategy past the present Trendy Slavery Act framework.
The proposal follows rising political and institutional stress to maneuver past the UK’s present transparency-based strategy. In early 2025, the Enterprise and Commerce Choose Committee signalled rising concern about forced-labour dangers and the necessity for stronger supply-chain accountability, and later in 2025 the Joint Committee on Human Rights formally beneficial obligatory human rights due diligence. Towards this backdrop, the Impartial Anti-Slavery Commissioner has now revealed mannequin laws setting out how a compulsory regime may work in apply.
What does the proposal contain, how wouldn’t it work in apply, what are the important thing dangers and, what ought to companies be doing now?
What the proposal would do
1. Obligatory human rights due diligence
On the coronary heart of the proposal is a requirement for firms to conduct obligatory human rights due diligence (MHRDD) throughout their operations and provide chains. This strikes effectively past the present Trendy Slavery Act’s reporting obligations, that are largely voluntary and centered on transparency fairly than prevention.
Beneath the proposal, an organization may very well be held accountable if a “severe human rights hurt” happens and the corporate:
- Brought about it
- Contributed to it
- Was straight linked to it by means of its enterprise relationships
Legal responsibility wouldn’t be automated. An organization would have a defence if it may show that it had carried out affordable human rights due diligence to determine, forestall and handle the danger. The place it can not accomplish that, it might face authorized penalties, with the mannequin legislation offering for each civil and felony legal responsibility in sure instances.
This strategy mirrors the UK’s established “failure to stop” framework, beneath which organisations are held accountable not as a result of hurt occurred, however as a result of they didn’t put enough preventive measures in place. Comparable fashions exist already beneath the Bribery Act and the Financial Crime and Company Transparency Act, and the proposal applies that logic to human rights danger inside company governance.
2. Compelled labour import and export ban
A central function could be a ban on importing, exporting or making accessible within the UK market items made with compelled labour. In contrast to the present strategy beneath the Trendy Slavery Act or different import controls, the proposed ban would additionally cowl transport and logistics providers the place compelled labour can happen.
This mirrors world tendencies. The EU, for instance, is introducing a compelled labour regulation that can ban merchandise made with compelled labour from its market.
3. New oversight and transparency mechanisms
The proposal would set up:
- A brand new Workplace for Accountable Enterprise Conduct inside the Division for Enterprise and Commerce to watch and implement compliance
- A public registry of annual human rights statements, changing the present Trendy Slavery Assertion regime to enhance transparency and accountability
Ministers could be required to make sure that all UK laws aligns with obligations to stop business-related human rights impacts.
Why this issues now
A voluntary reporting strategy has more and more been seen as inadequate. Evaluations by parliamentary committees, authorized commentators and civil society teams have highlighted that many Trendy Slavery Act statements lack substance and have didn’t drive significant change in enterprise behaviour. On the similar time, different jurisdictions are shifting in the direction of obligatory human rights due diligence, elevating considerations that the UK dangers falling behind worldwide friends.
The Impartial Anti-Slavery Commissioner’s proposal responds straight to those criticisms and to wider worldwide developments. It’s designed to carry UK legislation nearer into line with world requirements such because the UN Guiding Ideas on Enterprise and Human Rights and the OECD due diligence tips, which concentrate on figuring out, stopping, mitigating and remedying human rights hurt on a risk-based foundation.
Supporters of the mannequin legislation argue that this shift is crucial to shut enforcement gaps within the present regime and, critically, to enhance entry to treatment for staff affected by compelled labour and different severe abuses.
The sensible dangers and questions
Whereas the proposal is substantive, a number of sensible considerations have been raised, particularly round enforcement and resourcing.
Enforcement capability
A core query is who truly enforces the legislation and the way successfully. The proposal locations oversight with the Workplace for Accountable Enterprise Conduct, however:
- Resourcing for brand new enforcement our bodies is unsure
- Many authorities departments already face capability constraints
- Efficient enforcement would require sturdy coordination between customs authorities, regulators and prosecutors
With out clear funding and powers, enforcement may very well be gradual or reactive, leaving firms unclear about expectations.
Provide chain complexity
International worth chains are giant and opaque. Even refined firms can wrestle to map dangers past first-tier suppliers. Mandating due diligence raises the bar, however sensible implementation would require technical instruments, risk-based prioritisation and credible proof of actions taken.
Integration with different regimes
If the UK strikes forward with MHRDD alongside the EU’s rising company due diligence legal guidelines, firms working internationally will face overlapping necessities. That will increase compliance complexity but in addition underscores the worth of harmonising approaches the place doable.
Why enforcement should still work
There are causes to suppose enforcement may very well be efficient regardless of these challenges:
- Concentrate on prevention: The legislation is structured to encourage firms to spend money on due diligence techniques, fairly than ready for presidency inspections.
- Acquainted legal responsibility mannequin: The “failure to stop” framework is well-understood in UK company legislation, lowering uncertainty about authorized checks.
- Focused motion: Enforcement is prone to prioritise high-risk sectors and evidence-led investigations, which is extra sensible than blanket compliance checks.
This design displays classes from different UK regulatory regimes the place risk-based enforcement has pushed change with out extreme administrative burden.
What companies ought to do now
Regardless that this proposal is just not but legislation, the route of journey is evident. Companies that take steps now could have a head begin.
1. Embed human rights due diligence
Spend money on danger mapping, provider engagement and corrective motion plans that align with:
These frameworks are prone to type the spine of any future authorized obligations.
2. Construct functionality
Develop inner experience on human rights dangers and provide chain due diligence, together with coaching, information techniques and escalation pathways.
3. Interact constructively
Take part in consultations and stakeholder dialogues to form the ultimate type of the legislation. Many firms are already listening to from the Impartial Anti-Slavery Commissioner’s workplace as a part of early engagement.
4. Align with world necessities
Put together for overlapping worldwide obligations by monitoring developments within the EU, US and different jurisdictions.
The UK’s proposed enterprise and human rights legislation marks a shift from voluntary reporting to preventive accountability. It responds to long-standing considerations about compelled labour and weak enforcement beneath the Trendy Slavery Act, and displays a broader world development in the direction of obligatory due diligence.
For companies, this implies shifting past compliance as a reporting train in the direction of proactive danger administration, provider engagement and real human rights accountability.
Trendy slavery coaching helps your organization or agency keep away from being related to exercise that violates rules, both straight or by proxy by means of provider relationships. With a variety of choices, VinciWorks’ fashionable slavery coaching suite is designed to satisfy the wants of a complete group, from normal employees to procurement groups.
Strive it at this time.
