The UK modern slavery regime has faced scrutiny in recent years for failing to keep up with requirements in other jurisdictions. A recent UK government publication offers a timely and illustrative example of how UK modern slavery laws are being reviewed. The document outlines the Government’s response to various recommendations made by the Joint Committee on Human Rights (a Parliamentary body) in a July report titled Forced Labour in UK Supply Chains (Sixth Report of Session 2024–25 HC 633 / HL Paper 159).

Background to the Joint Committee’s Report

The Joint Committee’s July report follows an inquiry it conducted into how UK businesses and government policies address forced labour risks. The report sets out a number of bold recommendations (some of which we have included below) urging the Government to introduce new legislation, strengthen how the regime is enforced, consider consistency with EU supply chain due diligence legislation, improve transparency, and ensure ethical practices across procurement, trade, and supply chains.

The Government’s Response to the Joint Committee’s Report

The Government’s response published in October 2025 acknowledges the seriousness of forced labour and indicates that it will review a ‘range of measures’ to strengthen Section 54 of the Modern Slavery Act 2015 (i.e., the statutory requirement for commercial organisations above £36m annual turnover to produce modern slavery statements), including reporting rules, turnover thresholds, enforcement penalties, and extending its scope to public bodies. Nevertheless the Government response does not indicate that significant legislative action will be taken in the near future, instead highlighting the benefits of the revamped Home Office statutory guidance on the Modern Slavery Act 2015 updated earlier this year (which we wrote about here: SPB, ‘Supply Chain Transparency’, May 2025), and the creation of new bodies like the Office for Responsible Business Conduct and Great British Energy.

Conclusion

We’ve highlighted below some of the most significant Joint Committee recommendations, alongside the Government’s responses. While some of the commentary remains opaque at this stage, we expect further detail to follow in due course to give businesses more certainty on what sort of changes to the regime they can expect. In the meantime, businesses should focus on preparing their next modern slavery statements in line with the updated Home Office statutory guidance. If you would like to speak to us about a review of your modern slavery statements or any other matter, we would be happy to help.

Topic Recommendations of Joint Committee Government response to Joint Committee recommendation
UK Domestic Law Recommendation 1 – Introduce legislation to ban import/sale of goods linked to forced labour, mandate human rights due diligence, and allow civil claims.   “Building on the 5 principles of the Modern Slavery Act 2015 and the UN Guiding Principles on Business and Human Rights, the Government is actively exploring options to strengthen protections.   In the Trade Strategy, the Government launched a review of its approach to responsible business conduct policy, focused on the global supply chains of businesses operating in the UK. The review will be a neutral, objective appraisal of policy led by the Department of Business and Trade. It 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, while having due regard to costs on business and the approaches taken by our trading partners.   A range of measures are under consideration as part of the review, including many of those referenced by the Committee. Any future action will be carefully calibrated to ensure it supports UK businesses, complies with international obligations, and delivers meaningful outcomes.”  
The UK’s current approach to transparency reporting Recommendation 3 – Strengthen accountability for non-compliance under Section 54 of the Modern Slavery Act.   “The Home Office is actively considering legislative vehicles to strengthen the Act.”   “The Home Office has recently published updated Transparency in Supply Chains statutory guidance, which is now more comprehensive, practical and ambitious – calling on businesses to go further and faster in their efforts to eliminate modern slavery from their operations and supply chains.”   “The UK has spearheaded collaboration with the Australian and Canadian governments to publish a new transparency reporting template which supports businesses to produce one modern slavery statement for all three countries.”  
Recommendation 4 – Remove Section 54(4)(b) which allows companies to report no action taken.  
Recommendation 5 – Extend transparency reporting duties to public organisations.  
Human Rights Due Diligence (HRDD) Recommendation 6 – Legislate mandatory HRDD requirements for UK-trading businesses.   “In the Trade Strategy 2025 the Government launched a review into the UK’s approach to responsible business conduct, focused on the global supply chains of businesses operating in the UK. This includes consideration of mandatory human rights and environmental due diligence measures.”   “As an integral part of the review will be harnessing the insights and expertise of businesses, investors, trade unions, academia and civil society.”   “The FCDO is carrying out a National Baseline Assessment (NBA) on the implementation of the UN Guiding Principles on Business and Human Rights.”   “The Government has established the Office for Responsible Business Conduct (RBC) to replace the UK’s National Contact Point. This enhanced office will support industry to integrate responsible business practices into their operations. It will help victims of corporate malpractice through continuing to operate a non-judicial complaints mechanism for alleged violations of the OECD Guidelines on RBC.”  
Recommendation 7 – Align UK HRDD with EU’s Corporate Sustainability Due Diligence Directive.   “The RBC review will have due regard to the approaches taken by our trading partners, including the European Union. Noting the EU’s adoption of the Corporate Sustainability Due Diligence Directive, the Government has been in regular contact with the European Commission on this issue, including through the Trade Specialised Committee on Level Playing Field for Open and Fair Competition and Sustainable Development.”  
Recommendation 8 – Apply lighter, risk-based HRDD requirements for SMEs and support them with tools.   “The RBC review will consider the best way to promote a coordinated approach to responsible business that minimises costs to businesses, including SMEs. This will be consistent with the Prime Minister’s commitment to reduce the administrative cost of complying with regulation by 25% over the Parliament.”   “Through the review process we will engage with SMEs to harness their insights and expertise.”   “The [support] measures include cutting the administrative costs of regulation for business by 25% to save businesses time and money so they can focus on running successful businesses; and the launch of our new Business Growth Service, a new national service making it easier and quicker for businesses across the UK to get the help, support and advice they need to start, scale and succeed.”  
ImportBans   Recommendation 9 – Use the Supply Chain Centre to support companies with verified guidance.   “Responsibility for government policy on forced labour in supply chains sits with the Office for Responsible Business Conduct (ORBC) rather than the Supply Chain Centre, which will focus on building the resilience of the UK’s critical IS8 supply chains. ORBC works closely with the Supply Chain Centre and other parts of government to ensure a joined-up approach.”   “The RBC review will consider the effectiveness of the UK’s current regime and alternative means of supporting responsible business practices. Any policies developed following the review will consider a range of factors, including how to ensure company compliance and behaviour change.”   “We will wait for the review to conclude before making any decisions on whether a regulatory function is required.”  
Recommendation 10 – Establish effective regulatory arrangements with proportional penalties.  
Recommendation 11 – Assign regulatory responsibility to a well-resourced body like ORBC or the Supply Chain Centre.  
Recommendation 12 – Introduce an import ban on goods produced using forced labour, with clear enforcement mechanisms.   “We are actively reviewing the effectiveness of existing UK measures, including as part of the RBC review, and considering the implications of a variety of approaches to tackle forced labour in supply chains. We continue to engage with international partners to support our shared goal of combatting forced labour in supply chains.”  
Recommendation 13 – Ensure the ban includes goods linked to state-imposed forced labour.   “The Government remains firmly opposed to the use of state-imposed forced labour. We are considering how best to reflect this position within our broader frameworks for trade policy and responsible business conduct. It is important to consider the operational and legal complexities involved. We will continue to assess the most effective means of addressing this issue, including through existing due diligence and transparency mechanisms”  
Recommendation 14 – Enable Border Force officers to detect and act on forced labour-linked consignments.   “Tackling forced labour requires a whole-system approach of which the border is a part. Any approach would need to define the scale and scope of the activity alongside any potential legislative and resourcing requirements.”  
Recommendation 15 – Include a rebuttable presumption for goods from high-risk regions.   “We will continue to assess and evaluate the effectiveness of existing measures, including data-driven and risk-based approaches as well as where the burden of proof may sit.”  
Recommendation 16 – Designate a responsible body to oversee enforcement and coordination.   “The Government agrees that effective coordination is integral to tackling forced labour in supply chains. Decisions regarding oversight and enforcement of actions to tackle forced labour in supply chains will be 13 made in light of ongoing policy development and resource considerations. We remain committed to ensuring that any future arrangements are coherent, efficient, and capable of delivering meaningful impact.”  
Recommendation 17 – Use POCA powers to seize assets and prevent sale of forced labour-linked goods.   “POCA provides law enforcement agencies with a powerful range of powers to seize cash and assets from individuals profiting from criminal activity. Government cannot direct how the POCA powers are used by law enforcement and independent operational decisions are a matter for the NCA. Criminal investigations and prosecutions are dealt with on a case-by-case basis by the relevant agencies.”  
Great British Energy (GBE)   Recommendation 24 – GBE must report on anti-slavery measures and future plans within 12 months. “The Government is taking steps to address reports of forced labour in clean energy supply chains. This includes strengthened procurement rules and support for industry-led transparency initiatives, such as the Solar Stewardship Initiative. Great British Energy will follow strict ethical standards in procurement and work with civil society to help ensure supply chains are free from exploitation.”  
The UK’s demand for critical minerals Recommendation 25 – Outline steps in the Critical Minerals Strategy to reduce reliance on high-risk sources. “The UK Government places a high priority on mining and mineral processing being carried out to the highest environmental, social and governance (ESG) standards. We are committed to the sustainable development of natural resources in the UK and overseas. The new Critical Minerals Strategy, expected in 2025, will refine our approach to responsible and transparent supply chains.”