Modern slavery | UK Regulatory Outlook May 2026
Published on 27th May 2026
Independent Anti-Slavery Commissioner publishes futures analysis on modern slavery threats | GRETA urges stronger enforcement on labour exploitation and supply chain transparency in fourth UK evaluation report
Independent Anti-Slavery Commissioner publishes futures analysis on modern slavery threats
The Independent Anti-Slavery Commissioner has published a futures analysis report examining modern slavery and human trafficking threats in the UK through to 2036, drawing on contributions from more than 50 organisations and lived experience advisory panels.
The report identifies 21 threats across five thematic areas. It concludes that AI, cryptocurrencies and digital platforms are enabling traffickers to recruit, control and exploit victims with greater scale, speed and anonymity, while fragmented safeguarding systems and low prosecution rates are weakening the UK's response. It identifies a number of sectors as being at particular risk of labour exploitation, including care, logistics, food production, retail, construction, car washes, cannabis cultivation and platform-based work, with construction highlighted as being at especially high risk of exploitative practices and cash-intensive sectors such as nail bars also identified as areas where exploitation linked to organised crime is more likely (risks that are closely mirrored in GRETA's findings, discussed below). Among its recommendations are stronger labour protections, reform of tied visa arrangements, increased corporate accountability, greater regulation of digital platforms and supply chains and improved international cooperation.
The King's Speech announced an Immigration and Asylum Bill with proposals to reform the modern slavery legislative framework, focused on addressing potential misuse of the immigration system while maintaining essential protections. Notably absent, however, was any indication of a move towards increased proactive corporate obligations. The speech did not address the calls for reform of corporate reporting on modern slavery or the introduction of mandatory due diligence and forced labour frameworks. Companies with extended or internationally sourced supply chains should monitor the government's response to the Commissioner's recommendations, but there is currently no indication of changes to corporate obligations in the near future.
GRETA urges stronger enforcement on labour exploitation and supply chain transparency in fourth UK evaluation report
The Council of Europe's Group of Experts on Action against Trafficking in Human Beings (GRETA) has published its fourth evaluation report on the United Kingdom, with significant findings for employers and businesses on labour exploitation and supply chain accountability.
National Referral Mechanism (NRM) referrals increased sharply over the reporting period, rising from 12,691 in 2021 to 19,125 in 2024, with 17,397 referrals recorded in the first nine months of 2025 alone. Labour exploitation was the predominant form of trafficking overall, accounting for 29% of referrals between 2021 and 2024, predominantly affecting adult victims with foreign citizenship. High-risk sectors identified by GRETA include agriculture, care work, domestic work, hospitality, construction, fishing, car washes, nail bars, waste management, logistics, food processing and warehousing.
GRETA highlights fragmented labour enforcement and significant resource constraints, noting that the Gangmasters and Labour Abuse Authority had only 115 staff across the UK as of December 2024, conducted just 123 inspections in the year to March 2024 and referred only 44 possible victims to the NRM across the entire 2021 to 2024 period, while its budget fell from £7.77 million in 2023-24 to £6.26 million in 2024-25. GRETA welcomes the planned creation of the Fair Work Agency, merging the GLAA, the Employment Agency Standards Inspectorate and HMRC's National Minimum Wage team, but stresses that it must have a broad remit, adequate geographical coverage including territorial waters and sufficient resources to be effective.
On corporate accountability, GRETA notes that while companies with a turnover of £36 million or more supplying goods or services in the UK are required to publish annual modern slavery statements under section 54 of the Modern Slavery Act, there have been no sanctions for non-compliance and the injunction power has never been used, with measures to strengthen penalties and create a meaningful enforcement regime not yet adopted. GRETA calls for strengthening the prevention of trafficking in supply chains and improved enforcement of modern slavery statements.