Will UK Ramp Up Anti-Forced Labour Efforts in Supply Chains?
The UK government has set a firmer course on tackling forced labour in supply chains, launching a cross-Whitehall review of Responsible Business Conduct (RBC) and sharpening public procurement rules.
While there is no immediate new law, the policy direction is clear: stronger expectations on due diligence, more muscular use of procurement levers and closer alignment with trading partners.
Sir Chris Bryant MP, Minister of State for Trade, says: “Forced labour is an egregious and severe violation of human rights.
“The abhorrent practice of forced labour has no place in UK supply chains and the global economy.”
For boards and chief procurement officers, the message is plain. Treat labour risk as a strategic exposure, not simply a compliance checkbox.
What has changed now
Under the Procurement Act a central debarment list is now live for suppliers linked to modern slavery. Contracting authorities have a tougher exclusion regime and must notify cases to the Procurement Review Unit.
In the energy sector, Great British Energy (GBE) has been mandated to act as a pathfinder for ethical supply chains, publish a modern slavery statement and use termination powers where forced labour links are identified.
GBE will report progress in its first annual report by July 2026, setting an early benchmark for governance and transparency.
What is under review
The RBC review is examining options that include mandatory human rights and environmental due diligence, potential import controls and the enforcement model needed to make any rules credible. Ministers will decide on penalties and who should regulate once the review concludes.
The newly created Office for Responsible Business Conduct (ORBC) leads government work on supply chain harms and will help shape practical compliance monitoring. The government is also considering stronger reporting rules, whether to extend obligations to public bodies and penalties for non-compliance.
The current reporting threshold referenced is about US$46m annual turnover, which means larger firms remain in focus while expectations of cascading due diligence through tiers will intensify.
Trade and sector measures
Trade policy will continue to insert forced-labour provisions into Free Trade Agreements (FTAs), with recourse to implementation forums and dispute processes where required. The UK has held labour discussions with 14 FTA partners including exchanges on forced labour, signalling a tighter international baseline.
Clean energy is a priority test bed, as the Department for Energy Security and Net Zero (DESNZ) will embed ethical supply chains into growth plans.
The government says it welcomes the Solar Stewardship Initiative but says procurement will not rely on SSI alone; standards will be reviewed and action taken if gaps appear. A refreshed critical minerals strategy due in 2025 aims to strengthen responsible and transparent sourcing across strategic inputs.
Numbers leaders should note
- US$46m: current turnover threshold referenced for section 54 reporting
- 5.5 million: number of SMEs government aims to support through a wider package
- 25%: targeted reduction in administrative compliance costs across this Parliament
- 14: FTA partners with whom labour discussions have been held on forced labour
- April 2026: target for a new Fair Work Agency to be operational
- July 2026: GBE’s first annual report deadline
Large businesses above the section 54 threshold should move now by expanding risk mapping beyond first-tier suppliers and ensuring supplier onboarding is aligned to the new debarment regime.
Public-sector suppliers should expect closer scrutiny, tighter clauses and credible audit trails. Meanwhile, for SMEs, the focus is on salient risk hotspots, adopt recognised third-party standards where practical and document continuous improvement.
Buyers will expect progress in sectors with known exposure such as solar, electronics, garments and critical minerals.
