Modern slavery | UK Regulatory Outlook February 2026

EU consults on forced labour guidelines 

The European Commission has opened a call for evidence on guidelines for the implementation of EU rules on forced labour. The guidelines are mandated under EU legislation and must be issued by 14 June 2026. The guidelines aim to ensure a predictable and smooth implementation of the forced labour rules, while minimising burdens on administrations and companies. They will offer a structured framework to ensure compliance and effectiveness, clarifying roles and responsibilities, supporting capacity building, and promoting transparency and accountability. 

The feedback period opened on 6 February and runs to 6 March. The Commission is consulting with stakeholders, and feedback received will be published and taken into account as the guidelines are developed.  

The Commission is seeking specific feedback on several areas including:  

• The main types of evidence to be considered during investigations.
• The documentation that economic operators could provide during the preliminary investigation phase.
• Best practices for conducting forced-labour-related due diligence across product groups and economic sectors.
• Best practices for remediating forced labour and harm caused.
• Complementary resources that would be helpful for understanding and complying with the regulation.
• Training or capacity-building support for economic operators. 

Businesses should consider participating in this consultation to help shape the regulatory framework and ensure their operational concerns are reflected in future forced labour requirements. 

Anti-slavery commissioner proposes Forced Labour and Human Rights Bill 

The Independent Anti-Slavery Commissioner (IASC) has published a report proposing model draft legislation for a Forced Labour and Human Rights Bill that would introduce mandatory human rights supply-chain due diligence requirements, a forced labour products ban and annual human rights compliance reporting in the UK, replacing section 54 of the Modern Slavery Act 2015. 

The proposed bill would apply to commercial organisations with a turnover of £36 million or more and establish liability for serious human rights harms unless the organisation could prove it had conducted reasonable due diligence.  

Provisions include mandatory annual human rights statements published on websites, enforcement by a new Office for Responsible Business Conduct with powers to issue penalty notices of up to 5% of global turnover and exclude businesses from public procurement, civil liability for individuals to bring claims for up to six years with potential for exemplary damages, and criminal liability for businesses and senior officers responsible for serious human rights harms that would constitute criminal offences under UK law. 

The bill would also ban the export, import or supply of "forced labour products" (products made with or transported with forced labour), with fines of twice the sale value or up to 5% of annual turnover. A public forced labour database would provide information and enable tip-offs for suspected breaches. 

The IASC does not have legislative powers and cannot introduce a bill to Parliament directly. Any legislative change would require the government to bring forward its own bill, or for a Member of Parliament to introduce a Private Member's Bill. Given the current political climate and competing priorities, significant legislative change in the short term appears unlikely, though the detailed model drafting provides a clear framework should the political will emerge.