On the 25th of July 2025, the Joint Committee on Human Rights published its report on forced labour in global supply chains, following its inquiry into the UK’s existing legal and regulatory framework.
The report found that goods produced, or part produced, using forced labour are being imported and sold to UK consumers, revealing that current domestic legislation is failing to effectively prevent this exploitation.
The report recommended a number of legislative changes, which we summarise below.
Strengthening section 54 of the Modern Slavery Act 2015
When introduced in 2015, the Modern Slavery Act was considered world leading in its requirement for UK companies, with an annual turnover of £36 million or more, to declare the actions they had taken to combat modern slavery in their supply chains each year.
However, the Joint Committee’s report finds that the Act is not effectively motivating companies to meaningfully address forced labour in their supply chains, highlighting the gap between policy and practice.
The report recommends:
- Removal of s.54(4)(b) of the Act, to prevent companies from reporting that they have taken ‘no action’ to prevent slavery and human trafficking from taking place in business or supply chains.
- Extension of the statutory reporting duty to public organisations.
- Strengthening the reporting duty under s.54 by establishing effective accountability mechanisms for non-compliance.
Duty to Prevent Forced Labour
The Committee has called on the Government to introduce new legislation that would impose a legal duty on all companies to prevent human rights abuses in their operations and supply chains. If implemented, this obligation could give survivors a clearer route to justice through the UK courts.
The creation of a duty to prevent would effectively be a new cause of action, and failure to comply with would be the basis of a civil claim. The burden would be on the relevant corporation to demonstrate that they had adequate procedures in place designed to prevent such forced labour. If a company was found not to have adequate procedures in place, then they could be required to pay compensation to victims.
Mandatory Human Rights Due Diligence
Corporate due diligence requirements for supply chains in the UK are currently ‘voluntary’, leaving significant gaps in accountability. The Committee found that this approach is failing to effectively tackle forced labour. It recommends the implementation of mandatory human rights due diligence, which would level the playing field for businesses.
The Committee recognised that due diligence requirements should be proportionate for small and medium enterprises (SMEs) and therefore recommended that they are subject to lighter requirements.
If the Government adopts the Committee’s recommendations, UK companies will be required to significantly strengthen their efforts to combat forced labour in their supply chains. The government now has two months to respond to the recommendations.
If you require assistance in relation to compliance with the Modern Slavery Act 2015 or require any help updating your policies, please contact a member of our team: employment@wslaw.co.uk