Skadden, Arps, Slate, Meagher & Flom·ENVIRONMENT / ESG / CLIMATE

UK Pledges Mandatory Human Rights Due Diligence, Forced-Labour Import Powers

The UK government says it will legislate a mandatory human rights due diligence regime and gain power to remove forced-labour goods from the UK market; scope, thresholds and timing are not yet specified.

On 4 November 2026 the UK government announced its intention to legislate a mandatory human rights due diligence regime, and signalled that under it the government would gain power to remove goods made with forced labour from the UK. As reported by Skadden on 9 November 2026, this is legislative intent rather than enacted law: the available material does not set out covered entities, standards, enforcement mechanism or timetable, and does not confirm whether a consultation or draft bill has been published.

Why clients care: UK-facing supply chains — apparel, electronics, automotive components, food, consumer goods — are the obvious exposure. A statutory due diligence duty would convert what many companies still treat as voluntary ESG reporting into a legal obligation, with knock-on contract, disclosure and liability consequences. The market-access limb matters separately: a power to remove forced-labour goods would create direct import risk for goods at risk of a forced-labour finding, echoing the enforcement model US clients already navigate.

Practical next steps: treat supplier mapping, audit rights and evidentiary documentation as a live workstream, and stress-test import pathways for high-risk origins. Watch for the draft bill, the definition of forced labour, covered-entity thresholds, transition periods, and whether import powers attach to this regime or separate customs legislation. We cannot confirm when enabling legislation will be tabled.

human-rights-due-diligenceforced-laboursupply-chainesgimport-banuk-regulation
Read the original firm alert → Tuesday, November 10, 2026

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