UK Plans £350m Supply Chain Checks Against Forced Labour

10 November 2026
Curated by Vishaljeet Singh, Lisbon, Portugal

The United Kingdom is preparing a tougher legal framework to make large companies identify and address forced labour and human-rights abuses in their supply chains. Under the Government’s announced plan, mandatory human-rights due diligence would apply to UK businesses with annual global turnover above £350 million and overseas businesses generating more than £350 million in the UK.

The measures would cover services across the UK and goods in Great Britain. Regulators would also receive powers to investigate suspected forced-labour products and order their withdrawal from the Great Britain market where forced labour is identified and the business has failed to meet its due-diligence obligations. The announcement marks a significant proposed shift from a framework that ministers say has relied too heavily on voluntary reporting.

What has the UK Government announced?

Business Secretary Jonathan Reynolds set out the Government’s approach in a written ministerial statement on 4 November 2026, following a review of the UK’s responsible business conduct framework. The Business, Innovation and Science Committee highlighted the commitment on 9 November, describing it as a breakthrough after sustained parliamentary pressure for stronger action against forced labour in global supply chains.

The Government says the current system is fragmented and depends too heavily on voluntary action and reporting. It wants larger businesses with the resources and influence to identify exploitation risks to take a more active role in preventing abuse in their own operations and supply networks.

Which companies will be covered?

The announced turnover threshold is designed to focus the new duties on the largest businesses, rather than impose the same compliance burden on every small company. The proposed scope includes:

UK-based companies: Businesses with global annual turnover of more than £350 million.
Overseas companies: Businesses generating more than £350 million in turnover within the UK.
Services: The due-diligence regime is intended to apply across the UK.
Goods: The regime is intended to apply in Great Britain, with separate arrangements for Northern Ireland under the Windsor Framework.

The threshold means that many smaller suppliers may not be directly covered by the main legal duty. However, they could still face requests for information, audit evidence and corrective action from larger customers that must assess risks throughout their supply chains.

What will companies have to do?

Businesses within scope will be required to identify, assess and address risks of human-rights abuses and labour exploitation in their operations and supply chains. The Government says the framework will be risk-based and proportionate, and will draw on established international standards, including the OECD Guidelines for Responsible Business Conduct and the United Nations Guiding Principles on Business and Human Rights.

In practical terms, companies should expect to examine where their goods, raw materials and services come from; assess suppliers and higher-risk locations; investigate warning signs; and take steps when exploitation is identified. The final legislation will determine the precise procedures, reporting requirements, regulator powers and consequences for non-compliance.

Goods made with forced labour could be removed from the market

One of the most important parts of the proposal is the planned power to remove goods made with forced labour from the Great Britain market. A regulator would be able to investigate businesses suspected of placing such goods on the market. Where forced labour is identified and the relevant business has failed to meet its due-diligence obligations, the regulator could direct that the goods be withdrawn.

This is not simply a blanket ban on products from a particular country or industry. The announced approach links market withdrawal to the identification of forced labour and a failure to meet the required due-diligence standard. The detailed legal test and enforcement process will depend on the legislation and its implementing rules.

Why the Modern Slavery Act is being strengthened

The Modern Slavery Act 2015 introduced transparency requirements for large businesses, including a duty to publish statements describing the steps taken to address modern slavery risks. The Government’s review concluded that the existing framework is now fragmented and too dependent on voluntary action and reporting.

Parliamentary scrutiny also increased after a committee hearing with representatives of fashion retailer Shein, where the company’s representative repeatedly declined to confirm whether its products contained cotton sourced from China, including the Xinjiang region. The episode intensified calls for enforceable duties that require companies to investigate and address exploitation rather than simply publish statements.

The Business, Innovation and Trade Committee has argued that the UK should not become a destination for goods produced with exploitative labour, particularly when major trading partners are introducing stronger safeguards. Its latest announcement says the Government has now committed to legislating for mandatory due diligence.

What about Northern Ireland?

Northern Ireland has a distinct trading arrangement under the Windsor Framework. The Government has said that the EU Forced Labour Regulation will apply there, while the UK’s planned due-diligence regime will operate for services across the UK and goods in Great Britain.

The Government says the arrangements are intended to preserve Northern Ireland’s dual market access and avoid creating a new regulatory border within the UK. It expects the UK measures to achieve a similar practical outcome by identifying and addressing supply-chain risks before affected goods move through the Great Britain market.

When could the new rules take effect?

The Government has said that it will work with businesses and other stakeholders on the design and implementation of the measures and introduce them as soon as parliamentary time allows. The precise commencement date, transition period, regulator and detailed compliance requirements have not yet been set out in final legislation.

The Government’s Northern Ireland statement refers to an intended alignment with the EU rules in December 2027. Businesses should not assume that every operational detail or deadline is already final: the legislation and subsequent guidance will determine how and when the obligations apply.

What this means for retailers, manufacturers and suppliers

Large retailers, manufacturers, importers and service providers with complex international supply chains will need to prepare for closer scrutiny. Businesses may have to strengthen supplier onboarding, traceability systems, contract terms, risk assessments, grievance channels and procedures for responding to suspected labour exploitation.

Smaller suppliers could also feel the impact indirectly. Large customers may ask them for clearer origin records, workforce information, audit results and evidence that recruitment and working conditions meet legal standards. Suppliers that cannot provide credible information may find it harder to win or retain contracts.

For consumers, the objective is to reduce the risk that goods sold in the UK are linked to forced labour. For responsible businesses, stronger rules could also reduce the competitive advantage enjoyed by suppliers that cut costs through exploitation.

Why the policy matters beyond Britain

Global supply chains often cross several countries before a product reaches a shop or online marketplace. Raw materials may be extracted in one country, processed in another, assembled elsewhere and sold through a company headquartered in a different market. This makes it difficult for regulators and consumers to identify labour abuses without reliable records and cooperation across borders.

The UK’s approach is intended to bring its framework closer to international standards and the direction taken by major trading partners. It could influence how multinational businesses manage suppliers serving several markets, although differences between UK, EU and US rules will still need to be considered.

What businesses should watch next

Publication of draft legislation and the timetable for parliamentary consideration.
Confirmation of the regulator responsible for investigations and enforcement.
Detailed rules on risk assessment, evidence, remediation and market withdrawal.
Guidance on the £350 million turnover threshold and the treatment of corporate groups.
Implementation arrangements for Great Britain and Northern Ireland.

Bottom line

The UK’s proposed forced-labour rules would move supply-chain protection beyond a largely disclosure-based model and towards mandatory risk assessment and action by the largest businesses. Companies above the £350 million turnover threshold could face new responsibilities, while goods linked to forced labour may be withdrawn from the Great Britain market where legal conditions are met. The commitment is significant, but businesses and consumers will need to wait for the legislation, regulator and implementation timetable before the full impact becomes clear.

This report reflects the UK Government’s written statement of 4 November 2026 and parliamentary developments reported on 9–10 November 2026. The measures described are announced policy commitments and proposed legal powers; they should not be treated as fully operational rules until legislation and implementation details are confirmed.

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