Modern slavery | UK Regulatory Outlook January 2026

New NHS procurement regulations target modern slavery in supply chains

The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 were made on 17 November 2025 and are designed to help eradicate goods or services tainted by slavery and human trafficking in the NHS in England. Coming into force on 17 May 2026, the new regulations will apply to public bodies procuring goods or services for the purposes of the NHS in England, including central purchasing organisations and local authorities.

The regulations follow the government's consultation response earlier this year. A review delivered in December 2023 showed that across 60% of spend on medical consumables, 21% of suppliers were identified as high risk for modern slavery and 16% were medium risk, highlighting the need for standardised risk management across the NHS.

From 17 May 2026, in-scope public bodies will have to complete a modern slavery risk assessment before advertising a contract or framework opportunity where a competitive procedure is being used, or prior to contract award if competition is not used. They must then take reasonable and proportionate steps to address and, where practicable, eliminate any identified risks when designing the procurement procedure (such as by setting conditions of participation and award criteria), when setting the terms of the contract, and when managing the contract. The regulations will apply to all procurement activities undertaken by a public body, regardless of value, including those procurements covered under the Procurement Act 2023, those awarded under the Health Care Services (Provider Selection Regime) Regulations 2023 and any other procurement activity not covered by either of those regimes.

NHS England has updated draft statutory guidance, although the final version has not yet been announced, to which public bodies in scope for the regulations will need to have regard. The guidance sets out proposed reasonable steps public bodies should apply according to the level of modern slavery risk that has been assessed, including:

• For medium- and high-risk procurements, undertaking pre-market engagement to understand how supply chains respond to modern slavery risk.
• Including conditions of participation to ensure suppliers in scope of the Modern Slavery Act 2015 have a compliant modern slavery statement.
• Requiring completion of the Modern Slavery Assessment Tool (MSAT) within three months of contract award for medium-risk procurements, or as a condition of participation for high-risk procurements.
• Requiring KPIs on modern slavery in contracts such as sharing MSAT recommendations, handling confirmed cases within an agreed timeframe and requiring staff to complete modern slavery training.
• Taking a positive, proactive and collaborative approach with suppliers during contract management to foster transparency and encourage them to raise issues as they emerge.

Suppliers to the NHS should take steps now to ensure they meet the additional requirements that will be implemented in procurements from May 2026 onwards.

The European Forced Labour Regulation

The EU Forced Labour Regulation (Regulation 2024/3015) introduces a ban on products made with forced labour, ensuring they cannot be sold in the EU market. The regulation entered into force on 13 December 2024 and comes into full effect on 14 December 2027. With less than two years until full application, 2026 represents a critical year for businesses to prepare.

By 14 June, the European Commission will issue guidelines for the implementation of the regulation including due diligence, risk indicators and best practices. The Commission will also establish a public database by the same date providing indicative information on forced labour risks in specific geographic areas or products groups. Along with this, guidance on calculating financial penalties and applicable thresholds will be published allowing businesses to understand the full consequences of non-compliance.

UK companies that place or make available products on the EU market will be directly affected by this regulation, with products deemed to have been manufactured using forced labour being prohibited from being sold in the EU, and offending products being seized at EU borders. Companies should use the two-year implementation period to ensure compliance with the Forced Labour Regulation, as the penalties could cause significant business disruption, including reduced revenue and increased reputational risk. Please see our Insight for details on what businesses should be doing now to prepare for the 14 December 2027 deadline.

Update on changes agreed to CSRD and CSDDD

See ESG section.