Joint Committee on Human Rights publishes report on forced labour in UK supply chains

On 24 July 2025, the UK Parliament’s Joint Committee on Human Rights (the “Committee”) published  a report summarising the conclusions from its inquiry into the UK’s current legal and voluntary framework on forced labour in international supply chains.

Key conclusions

The Committee:

• found that the UK’s patchwork of domestic legislation relevant to forced labour and supply chains has not prevented goods linked to forced labour from entering the UK market;
• concluded that the UK is falling behind its main trading partners (such as the US and EU) in its approach to addressing forced labour in supply chains and new legislation is needed to ensure that the UK market is protected from goods tainted by forced labour;
• recommended the introduction of new legislation within one year that covers a new mandatory human rights due diligence duty, a right of action for victims of forced labour and a targeted import ban, as well as updates to the existing Modern Slavery Act 2015 (“MSA”); and 
• made several recommendations falling short of new legislation, including making it an explicit Government policy to include provisions concerning forced labour in future trade deals.

Impact on businesses

The Committee’s wide-ranging recommendations, if adopted, would require UK companies to significantly increase their activities to tackle forced labour in their supply chains. 

On top of the existing reporting requirement, certain companies in the UK would have to carry out due diligence across their supply chains to: (i) comply with a new human rights due diligence law; (ii) ensure its goods are not subject to an import ban; and (iii) help minimise the risk of being subject to civil claims for failure to prevent forced labour. 

However, it is not yet clear how far the Government will go in actioning the recommendations. While it has shown an interest in strengthening the reporting requirements under the MSA, changes to the regime have long been promised but seen little action taken. Given the recent updated Guidance (see our blog post), and newly developed international reporting template, it may be that further changes are put on hold. The Government may also be wary of the reaction to the EU’s Corporate Sustainability Due Diligence Directive (“CSDDD”) and delay any immediate discussion on introducing a human rights due diligence law until the CSDDD’s future has been resolved (see our CSDDD materials). 

Amendments to the Modern Slavery Act 2015

The Committee noted that the MSA was world leading when it introduced the UK’s first corporate reporting requirements for slavery and forced labour practices in supply chains in 2015. However, it concluded that compliance with the reporting duty is low and that it is not effective in preventing forced labour in supply chains. Key reasons highlighted for this failure were the lack of incentive for meaningful engagement (as organisations can report they have taken no steps to address forced labour) and the lack of obligation to evidence claims made in reporting. 

The Committee noted that the Government has confirmed that it is considering how to strengthen the section 54 MSA reporting requirement. It recommends that this is done by: (i) establishing effective accountability mechanisms for non-compliance; and (ii) removing section 54(4)(b), which allows companies to comply by reporting that no action has been taken. 

Mandatory Human Rights due diligence

The Committee observed that current due diligence requirements for supply chains in the UK are voluntary, but that it had seen evidence showing there is a desire amongst some businesses for the introduction of mandatory cross-sector human rights due diligence standards (partly to provide a level playing field). 

The Committee recommended the Government introduce mandatory human rights due diligence requirements throughout supply chains for businesses trading in the UK, with small and medium enterprises (“SMEs”) subject to lighter requirements. The new regime should be proportional and risk-based, with penalties for non-compliance based on company turnover.  

The Committee did acknowledge the challenges with implementing mandatory human rights due diligence, including lack of available supply chain data and difficulties accessing suppliers beyond tier 1. Consequently, the Committee recommended the Government’s newly announced Supply Chain Centre support companies in conducting effective due diligence by providing a single point of access to verified information, guidance and resources.

It was also noted that any UK regime should be mindful of the outcome of proposed revisions to the CSDDD in the EU. This is to ensure that businesses operating in both markets are not placed under conflicting regulatory burdens.

Import ban

Import bans are noted to play a particularly important role in relation to state imposed forced labour, where it is not appropriate or possible to for corporates to use leverage to improve working conditions. The Committee identified the US import ban regime as a successful example of what an import ban can be, calling out the rebuttable presumption as allowing US authorities to seize goods without the need for costly and lengthy investigations, whilst being balanced by the avenue to challenge such presumption. The Committee also pointed to the EU’s new Forced Labour Regulation (see our blog post) and warned the UK’s lack of equivalent legislation puts it at risk of becoming a market for goods unable to be sold elsewhere.

The Committee recommended the Government introduce an import ban on goods made using forced labour. It recommended the ban include a rebuttable presumption that goods linked to regions where the UK Government considers that state-imposed forced labour is occurring are deemed linked to forced labour until proven otherwise.

Duty to prevent

In one of its most significant developments, the Committee explained that survivors of forced labour in UK supply chains face significant obstacles to accessing justice in the jurisdictions where the abuse occurred, but that bringing cases in UK courts can also be very challenging (see our blog post).

Building on its predecessor’s recommendation in 2017 that a ‘duty to prevent’ should be adopted in the UK (modelled on the Bribery Act 2010), the Committee recommended that the Government creates a civil cause of action of failure to prevent forced labour. The burden would be placed on the relevant corporation to prove that they had adequate procedures in place to prevent such forced labour, for example through due diligence processes. 

Further reading

For more information on the UK modern slavery regime and business and human rights more widely, see our materials:

• UK government publishes updated guidance on modern slavery reporting: what this means for businesses
• UK government responds to House of Lords Select Committee Report on Modern Slavery Act 2015
• Key recommendations from House of Lords Select Committee report on the UK's Modern Slavery Act 2015
• One small benchmark for modern slavery reporting, one larger lesson for sustainability reporting
• Unpacking the UK Modern Slavery Act 2015 eight years on
• EU CSDDD materials, including proposed changes under the EU Omnibus 
• Business and Human Rights materials