UK to Mandate Supply Chain Human Rights Due Diligence for £350m+ Firms

Companies with revenues above £350 million ($470 million) will face mandatory human rights due diligence obligations across their operations and supply chains under legislation the UK government has committed to introduce.

The regime will apply to UK companies above the £350 million revenue threshold, as well as non-UK businesses generating more than £350 million in UK revenue. The government framed the scope deliberately, targeting the largest businesses "with the capability and leverage to manage these risks within their supply chains."

Business and Trade Secretary Jonathan Reynolds announced the plans, which follow a government review of the UK's approach to promoting Responsible Business Conduct. Reynolds said the review "found the UK's current framework for preventing forced labour to be fragmented and overly reliant on voluntary action and reporting measures," placing the UK "out-of-step" with other major economies.

What does the law require?

Under the new due diligence regime, in-companies will need to identify, assess and address risks of human rights abuses and labor exploitation within their operations and supply chains. The legislation is anticipated to align with established international standards, including the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.

The obligations extend beyond reporting. Reynolds confirmed the legislation will include enforcement powers, with a regulator empowered to investigate businesses suspected of placing goods made with forced labor on the market. That regulator can direct the withdrawal of those goods where due diligence obligations have not been met and forced labor is identified.

Reynolds said: "This package will safeguard the competitiveness of responsible businesses, strengthen confidence in UK markets and help ensure that goods linked to forced labour do not reach UK consumers."

Why now?

The announcement carries a clear trade dimension. Earlier this year, the US Trade Representative listed the UK among trading partners that have failed to effectively enforce a ban on importing goods produced with forced labor, and Washington responded with new tariffs on UK imports.

The UK's review predates those tariffs. Still, the government's announcement explicitly highlighted the need to bring its rules into line with major trading partners, linking the domestic due diligence regime to market access abroad.

For materials-intensive supply chains, the move signals a continued tightening of compliance expectations. Importers and manufacturers operating at scale in the UK will need documented risk assessment and remediation processes for labor exploitation, not voluntary pledges or reporting exercises.

What happens next?

The next milestone is the drafting of the legislation itself. The government has committed to introduce the regime but has not yet published a bill, set a commencement date, or named the regulator that will hold the investigation and withdrawal powers.

Businesses above the threshold will want to watch three details as the bill emerges: the precise scope of covered supply chain tiers, the enforcement mechanics behind product withdrawal, and the timeline for compliance before the regulator gains its powers. Until those parameters land in legislation, the £350 million threshold and the enforcement framework remain commitments to track rather than obligations in force.