UK: IASC report proposes new measures to strengthen human rights and forced labour framework

The best Christmas present can often be that little last one tucked at the bottom of your stocking – the late surprise entry making it all the more exciting. 

The same could be said of the UK Independent Anti-Slavery Commissioner’s (IASC) December 2025 report on Strengthening the UK’s Forced Labour and Human Rights Legislative Framework, with its “Model Legislative Drafting”, which could bring significant change to the UK business and human rights landscape. 

Key takeaways

• Failure to prevent offence: Similar to the AML/ABC space, the IASC has proposed a failure to prevent offence linked to serious human rights harms. This would include a reasonable due diligence defence and would apply to a broad range of companies, with the scoping test based on the current Modern Slavery Act 2015 with its £36m turnover threshold.
• Financial institutions & services: Unlike the EU Corporate Sustainability Due Diligence Directive (CSDDD or CS3D), the IASC’s proposed regime would not carve out financial institutions and would capture financial services, including investments and advisory services offered by investment managers.
• Civil & criminal liability: The proposal introduces the potential for regulatory fines for a variety of offences (up to 5% turnover), civil liability (granting impacted stakeholders and their representatives a direct cause of action, including the possibility for exemplary damages and account of profits) and criminal liability (for egregious harms that would be criminal offences under UK law) with unlimited fines and the possibility for director liability (where they consent or connive to the conduct).
• Forced labour ban: As well as a due diligence regime, the proposal includes a market access regime, proposing a ban on the export, import or making available of forced labour products (i.e., those made or transported with forced labour, including intermingled goods).
• Reporting: Section 54 of the Modern Slavery Act 2015 would (finally) be replaced with a broader human rights due diligence disclosure regime (via online annual statement) – with the reporting requirement backed by financial penalties. 

Reason for caution – and next steps

We have seen several attempts over the years to build on the UK’s previously innovative Modern Slavery Act with its corporate reporting requirement, none of which have been particularly successful. From House of Lords Private Members’ Bills, to Queen’s/King’s Speech commitments, the ten year anniversary of the Modern Slavery Act passed this year without significant amendment. 

However, the new IASC report does come as part of a growing tide of calls for change. The House of Lords Select Committee on the Modern Slavery Act 2015 and the UK Parliamentary Joint Committee on Human Rights both made recommendations to overhaul the current regime and introduce some of the measures which are reflected in the IASC’s report. With the EU finally settling its own position on the CSDDD, there is also now no reason for the UK government to delay waiting on the outcome of the EU's Omnibus discussions. 

Despite this, the current UK government is likely to be slow to pick up on the IASC’s recommendations – certainly wholesale. As it deals with a number of other issues (including upcoming local elections in 2026), the business and human rights landscape has not, to date, been a particular focus for the current government and a wide-ranging new human rights regime could also come into conflict with promises around cutting red tape and limiting regulatory burden. 

That does not mean certain elements of the IASC report might not be picked up at some point and this continues to be one to watch – especially now the IASC has gone to the effort of preparing a draft legislative proposal. 

For more information on the current modern slavery regime and previous calls for change, see our Quick Guide: Key Sustainability Disclosure Regimes: UK Modern Slavery Act 2015: modern slavery statements.