UK Corporate Human Rights Compliance Developments – Four Laws and Regulations to Watch

Over the last few weeks, the UK government has taken steps to enhance the Modern Slavery Act and develop deforestation regulations that will create new due diligence obligations. In addition, mandatory human rights and environmental due diligence legislation was introduced in the House of Lords. New government procurement requirements to combat modern slavery in supply chains also recently took effect. These initiatives – which have the potential to create significant new compliance obligations for US-based multinationals doing business in the UK – are further discussed in this post.  

Government Proposes Enhancements to the Modern Slavery Act

As part of a broader Home Office Immigration and Asylum Bill introduced in the House of Commons on June 30, the government is proposing enhancements to the Modern Slavery Act adopted in 2015. The Immigration and Asylum Bill is still in its early stages. It is scheduled to have its second reading in the House of Commons on July 13. 

The proposed enhancements to the transparency provisions of the Modern Slavery Act have been a long time in the making. In September 2020, the UK government published its response to a 2019 public consultation on the Modern Slavery Act. In that response, the government indicated it is “committing to an ambitious package of measures to strengthen and future-proof the Modern Slavery Act’s transparency legislation.” The changes contemplated by the Immigration and Asylum Bill are largely aligned with that package. The 2020 response is further discussed in this Ropes & Gray client Alert.

A July 2025 report by the UK Parliament’s Joint Committee on Human Rights also recommended enhancements to some aspects of the Modern Slavery Act. That report is discussed in this Ropes & Gray post.

Statement Content

Reporting would shift from a principles-based approach with suggested topical content to mandatory topical disclosures. These disclosures, which are broadly in line with modern slavery statement reporting requirements in other jurisdictions, relate to:

• the reporting entity’s structure, operations and supply chains;

• the steps taken to identify and mitigate against risks of slavery and human trafficking;

• policies;

• due diligence processes;

• staff training; and

• the effectiveness of the steps taken to ensure that slavery and human trafficking is not taking place in the reporting entity’s operations or supply chains.

The Secretary of State could by regulation add, amend or remove a disclosure requirement. It also could issue guidance regarding mandatory or voluntary disclosures.

Approval and Signature 

The parent of a reporting entity would expressly be permitted to approve and sign the statement. Although this is not addressed in the current statute, it reflects common practice.

The statement would have to include a declaration by the signatory that the statement is accurate to the best of the signatory’s knowledge and belief. This is similar to the attestation required by Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act.

The statement also would be required to indicate the date on which it was approved and signed. This change aligns with current Home Office recommended practice.

Publication and Submission 

The Secretary of State would expressly be empowered to adopt regulations requiring electronic submission of the statement. Posting to the government’s registry is currently voluntary. Company website publication would continue to be required.

The statement would be required to be published within six months after the financial year-end. Although encouraged, this is not currently required. The Secretary of State could further amend the due date.

Enforcement

A frequent criticism of the current Modern Slavery Act is that it lacks a robust enforcement mechanism. The proposed amendments would allow the Secretary of State to adopt financial penalties for non-compliance up to the greater of 1% of the reporting entity’s total turnover and £1 million.

New NHS Procurement Requirements to Combat Modern Slavery Take Effect

The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 took effect on May 17. 

The Regulations generally require public bodies procuring goods or services for the health service in England to assess the risk that slavery and human trafficking is taking place in the supply chain for the good or service.

The public body must take reasonable steps to address and where practicable eliminate the identified modern slavery risk. Under the Regulations, reasonable steps may relate to the (1) conditions for participating in the procurement process, (2) award criteria and (3) contractual terms. Contractual terms may include:

• requiring the supplier to conduct due diligence on modern slavery risks at subcontractors or other participants in the supplier’s supply chain and to address those risks;

• reporting the names and contact details of subcontractors or other participants in the supply chain;

• keeping supply chain traceability records and making those records available to the public body;

• taking necessary corrective actions or reasonable steps to remedy identified incidences of slavery and human trafficking; and 

• cooperating with government investigations.

Reasonable steps also may include monitoring supplier compliance with the terms of the contract, among others.

Although the Regulations do not directly create obligations for government suppliers, they may via contract require enhancements to modern slavery due diligence and related compliance procedures.

Deforestation Due Diligence Regulations to Be Introduced 

The Environment Act adopted in 2021 set a framework for addressing deforestation – under the Act, a regulated person may not use a forest risk commodity or a derived product in their UK commercial activities unless such person complies with relevant local laws – but it left many of the details to secondary regulation. For example, when the Act was passed, it deferred on the forest risk commodities that initially would be regulated and the compliance threshold.

Following a consultation process, in December 2023, the UK Department for Environment, Food & Rural Affairs (Defra) issued a press release announcing plans to introduce regulations addressing these and other details of the Act, as further discussed in this Ropes & Gray post. However, regulations did not materialize.

The regulatory process appears to again be underway. On June 23, during London Climate Action Week, the government announced that it intends to introduce deforestation regulations under the Environment Act.

In a policy paper also issued on June 23, Defra indicated that the government aims to require businesses in Great Britain with annual turnover of more than £1 million that use forest risk commodities and wood products to carry out due diligence to ensure the commodities and products are produced in compliance with relevant local laws.

These requirements will apply to (1) wood, (2) cattle, (3) cocoa, (4) coffee, (5) palm oil, (6) rubber, (7) soy and (8) certain derived products. Businesses who use these products will need to have a due diligence system, report on their activity and maintain proof of compliance by collecting geolocation data.

Defra indicated that the government aims to ensure its measures operate consistently alongside the EU Deforestation Regulation. The information Great Britain businesses must hold will be broadly the same as that needed for a due diligence statement when exporting to the EU or moving goods to Northern Ireland under the EUDR.

Defra has indicated that implementing legislation is expected to be delivered in 2027.

Mandatory Human Rights and Environmental Due Diligence Legislation Proposed

On June 17, a mandatory human rights and environmental due diligence bill was introduced in the House of Lords. This private members’ bill – the Commercial Organisations and Public Authorities Duty (Human Rights and Environment) Bill – was introduced by Baroness Young of Hornsey. Baroness Young previously introduced a similar bill in 2023, as discussed in this Ropes & Gray post.   

Most private members’ bills do not become law and the likelihood of passage of this bill in its current form is exceedingly slim. However, given the momentum behind mandatory human rights and environmental due diligence legislation in several jurisdictions, it bears watching. In its July 2025 report, the UK Parliament’s Joint Committee advocated for mandatory human rights due diligence requirements, among other support in the UK.    

The bill proposes to create a duty to prevent human rights and environmental harms in subject companies’ own operations and their value chains. This would include in particular an obligation to conduct iterative human rights and environmental due diligence. Subject companies would include UK-organized entities and other entities that carry on at least part of their business in the United Kingdom. Subject companies with annual worldwide turnover of at least £36 million would have an annual reporting obligation, as further discussed below.

“Human rights harms” are proposed to include any adverse impacts on a person’s or a group’s ability to enjoy any of the internationally recognized individual or collective human rights, including but not limited to those recognized in the United Nations International Bill of Human Rights and the United Nations resolution on the Right to a Clean, Healthy and Sustainable Environment, and all internationally or locally recognized labor rights, including but not limited to those recognized in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.

“Environmental harms” would include any adverse impacts, including harm resulting from cumulative impacts, on the environment or ecosystems, including but not limited to (1) climate change, (2) biodiversity loss, (3) degradation of land, marine and freshwater ecosystems, (4) deforestation, (5) air, water and soil pollution and (6) mismanagement of waste, including hazardous substances. These impacts would be required to be interpreted on the basis of the best available science and in line with relevant internationally recognized environmental principles and conventions, including the Paris Agreement, and locally applicable environmental laws, regulations and administrative practices.

Due Diligence

Reasonable due diligence would be required to include, at a minimum:

• informed, meaningful and safe engagement with rightsholders throughout the entire process; 

• integrating gender-responsive human rights and environmental due diligence procedures into policies and management systems; 

• identifying, assessing and addressing actual or potential human rights and environmental harms as well as vulnerability to the impacts of climate change, through prevention, mitigation and remediation, taking into account accurate baseline environmental conditions; 

• establishing or participating in and maintaining an effective grievance mechanism in line with the effectiveness criteria set out in United Nations Guiding Principle 31; 

• tracking, verifying, monitoring and assessing the effectiveness of the measures taken to reduce or mitigate harms and their outcomes; 

• reviewing and improving measures based on the outcomes; and

• communicating with stakeholders and reporting publicly on findings. 

Whether due diligence is “reasonable” would be facts-and-circumstances-based, taking into account among other things:

• the company’s size, sector, operational context, area of operation and nature of the harms in question;

• the severity of the harm;

• the company’s leverage;

• the prioritization of human rights and environmental risks within the company’s due diligence process;

• the extent to which due diligence was heightened and proportionate to the specific circumstances;

• the extent to which due diligence was exercised as an ongoing process with continuous monitoring and improvement;

• whether the measures taken substantially mitigated or prevented human rights or environmental harm within a reasonable time;

• the extent to which the company sought to minimize its emissions and its impact on carbon sinks from its own activities and value chains;

• the extent to which the company examined its purchasing practices and modified them where necessary to prevent harm; and

• the extent to which the company has remedied any harm in agreement with affected rightsholders.

Audit reports, certification schemes and membership in industry or multi-stakeholder initiatives for dialogue and learning would not be sufficient on their own to fulfill the due diligence obligation.

Suspension or termination of a business relationship would be required under certain circumstances as part of ongoing human rights and environmental due diligence. Disengagement would be required to follow specified process requirements not discussed in this post.

Reporting and Information Rights

Companies that meet the £36 million turnover threshold would be required to annually report. The report would be required to include (1) a report on the fulfilment of the company’s due diligence obligations (the bill includes additional detail on this element of the report); (2) full accessible and searchable disclosure of the reporting company’s value chain, including geolocation, enabling end-to-end traceability of goods and services; (3) full accessible and searchable disclosure of ownership structures; and (4) disclosure of grievances with regard to human rights and environmental harms and status of remedy. The report would be required to be independently verified by relevant rightsholders, including workers, trade unions, indigenous peoples and those representing human rights and the environment, in accordance with standards to be prescribed.

Third parties would have information rights. Upon written request, any person would have a right to accessible, credible and accurate information from a reporting company on how it prevents actual or potential human rights and environmental harm relating to a specific product, service, operation or value chain actor, including human rights and environmental baseline and impact assessments.

Third-party Liability and Penalties

A subject company would be liable for human rights or environmental harms in its own operations, products and services and throughout its value chains if it failed to take all reasonable steps to prevent the harm from occurring, including but not limited to conducting reasonable human rights and environmental due diligence. Remedies could include among others monetary damages and injunctive orders and orders to cease or desist. Trade unions, civil society organizations or other relevant actors acting in the public interest could bring actions on behalf of victims of adverse impacts.

A subject company also could be subject to fines of up to 10% of its global turnover. 

Under certain circumstances described in the bill, individual directors could be held liable for the subject company’s non-compliance, with the potential for fines and even imprisonment.

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