Regulatory Outlook

Modern slavery | UK Regulatory Outlook June 2026

Published on 30th June 2026

CPS publishes Serious and Economic Organised Crime Strategy 2030 | Private Members' Bill proposes mandatory human rights and environmental due diligence | European Commission consults on CSDDD implementation guidelines

CPS publishes Serious and Economic Organised Crime Strategy 2030

The Crown Prosecution Service has published its Serious and Economic Organised Crime Strategy 2030, replacing the previous Economic Crime 2025 Strategy with a broader approach that explicitly includes modern slavery, criminal exploitation and human trafficking within its scope. The strategy reflects the growing convergence between fraud, organised crime, cyber offending and hostile state activity, and specifically highlights the increasing prevalence of so-called "scam factories", large-scale criminal operations where individuals may be trafficked, coerced or otherwise exploited into committing criminal acts, blurring traditional distinctions between victims and offenders.

Under the strategy, the CPS has committed to delivering updated modern slavery training to reflect emerging issues, sharing best practice and encouraging closer engagement with policing at the outset of cases. More broadly, the strategy places significant emphasis on early prosecutorial engagement with law enforcement and embeds asset recovery as a routine element of case strategy from the outset of SEOC cases.

The combination of updated prosecutor training, closer early engagement with policing and a forthcoming review of prosecution guidance points to more effective investigation and prosecution of modern slavery cases. Businesses should expect this sharper prosecutorial focus to extend to supply chain criminality in the UK. As we previously reported, the Court of Appeal's decision in R (on the application of World Uyghur Congress) v National Crime Agency confirmed that businesses can face criminal liability, including money laundering offences under the Proceeds of Crime Act 2002, where forced labour or other criminality exists in their supply chains, even where the goods in question are obtained for adequate consideration. With the CPS now explicitly embedding modern slavery and criminal exploitation within its serious and organised crime framework, businesses should ensure they have strong supply chain due diligence measures in place to manage the increased risk of criminal liability exposure.

Private Members' Bill proposes mandatory human rights and environmental due diligence

See ESG section.

European Commission consults on CSDDD implementation guidelines

See ESG section. 

View the full Regulatory Outlook

Interested in hearing more? Read all the articles in our Regulatory Outlook series

Expand
Receive Regulatory Outlook each month

A round-up of upcoming regulatory developments – straight to your inbox

* This article is current as of the date of its publication and does not necessarily reflect the present state of the law or relevant regulation.

Connect with one of our experts

Interested in hearing more from Osborne Clarke?