Modern slavery | UK Regulatory Outlook July 2026

UK Immigration and Asylum Bill proposes to strengthen modern slavery reporting framework 

The government's Immigration and Asylum Bill, presented to Parliament on 30 June, proposes changes to the reporting regime under section 54 of the Modern Slavery Act 2015, which requires commercial organisations with annual turnover of £36 million or more to publish an annual slavery and human trafficking statement. 

The bill's principal proposals include prescribed content requirements for modern slavery statements, with greater emphasis on accountability and a requirement that organisations to explain why certain steps have not been taken.  

Among the specific proposals, organisations would be required to include an accuracy statement from the relevant signatory, with parent undertakings permitted to sign on behalf of subsidiaries. The bill would also extend reporting obligations to public bodies whose budget meets a threshold to be set in secondary legislation and would require statements to the secretary of state by specified electronic means. A financial penalty regime for non-compliance of up to the greater of £1 million or 1% of total turnover. 

The bill does not include mandatory human rights due diligence obligations, an omission already criticised by the Independent Anti-Slavery Commissioner. The bill passed its second reading on 13 July by 264 votes to 90 and will now proceed to committee stage. The House of Commons Public Bill Committee, which will meet for the first time to scrutinise the bill on 10 September, has issued a call for evidence and is accepting written submissions. The committee is expected to report by 3 November. 

European Commission publishes guidelines on the Forced Labour Products Regulation 

The European Commission has published guidelines on the application of the Forced Labour Products Regulation (FLPR) and launched a new Forced Labour Single Portal, providing businesses and other stakeholders with practical guidance ahead of the regulation's enforcement date of 14 December 2027. The guidelines are addressed to competent authorities, customs authorities, businesses and consumer associations, and are not legally binding. 

The FLPR prohibits the placing of products made with forced labour on the EU market and their export from the EU. It covers all products regardless of origin, type or sector, whether made in whole or in part with forced labour at any stage of the supply chain, and applies to all economic operators, including non-EU businesses. 

The guidelines cover the scope of the regulation, including the definition and risk indicators of forced labour, as well as the investigation and enforcement process, including how investigations are prioritised and how penalties are calculated. They also included non-binding due diligence guidance for businesses, based on the Organisation for Economic Co-operation and Development (OECD) six-step framework, which cover risk identification and assessment, prevention and mitigation, monitoring, external communication and remediation. 

Published well ahead of the December 2027 enforcement date, the guidelines give companies time to map forced labour risks across their supply chains and align test their due diligence frameworks against the OECD model.