Modern slavery | UK Regulatory Outlook October 2025

Cabinet Office publishes Anti-slavery Risk Tiering Tool and guidance document 

On 16 October, the Cabinet Office published an updated Anti-slavery Risk Tiering Tool (ARTT) and associated guidance. The ARTT represents a collaboration between a number of different governmental departments, including the Ministry of Housing, Food and Rural Affairs, the Home Office, and the Foreign, Commonwealth and Development Office. It now incorporates the latest risks and requirements, including those introduced by the Procurement Act 2023. 

The updated tool is designed to be more efficient than its previous versions, incorporating best practices and risk data from across government, and has been updated with the commercial lifecycle in mind. As the tool is itself an Excel sheet, it is also adaptable to a given organisation's needs and can be tailored to a particular risk appetite. 

The aim of the updated tool is to provide an immediate and practical way to support compliance with Procurement Policy Note 009: Tackling modern slavery in government supply chains and the government hopes that it will enable faster, more consistent risk assessments in future.  

Government responds to the Joint Committee on Human Rights report on forced labour in supply chains 

The government has now published its response to the House of Commons Joint Committee on Human Rights report from July on forced labour in UK supply chains. 

The response acknowledges that while section 54 of the Modern Slavery Act 2015 established the UK as the first country in the world to require businesses to report on how they are tackling modern slavery, a decade after the Act the UK's approach needs to evolve. The government will consider how it may strengthen the section 54 regime, including the reporting requirements, turnover threshold, penalties for non-compliance and the regime's application to public bodies. 

The government has launched a comprehensive review of its approach to responsible business conduct policy, focused on the global supply chains of businesses operating in the UK, as part of its trade strategy. This review will consider the best way to promote a coordinated approach to responsible business conduct, ensuring businesses respect human rights, labour rights, the environment and anti-corruption measures across their operations and supply chains. A range of measures are under consideration as part of the review, including mandatory human rights due diligence requirements, import bans on goods produced using forced labour and enhanced enforcement mechanisms, mirroring pro-active measures recently introduced under EU legislation.  

The response notes that this significant long-term reform will take time. In the interim, the Home Office has recently published updated Transparency in Supply Chains statutory guidance calling on businesses to go further and faster in their efforts to eliminate modern slavery from their operations and supply chains. The UK is also collaborating with the Australian and Canadian governments to publish a new transparency reporting template which will support businesses to produce one modern slavery statement for all three countries, and which is intended to help to reduce the administrative burden while providing businesses with one clear and consistent message on what good practice reporting looks like.