The UK's Modern Slavery Act Is Falling Short
The UK Modern Slavery Act 2015 was a landmark piece of legislation when it passed, requiring companies with annual turnover of £36 million or more to publish annual slavery and human trafficking statements outlining steps taken to prevent forced labour in their operations and supply chains. For nearly a decade, this transparency-based approach served as the backbone of the UK's anti-forced-labour framework. However, a growing body of evidence now shows it is not working as intended. In July 2025, the UK Parliament's Joint Committee on Human Rights published a comprehensive report on forced labour in UK supply chains, concluding that the UK's legal and regulatory frameworks are inadequate for confronting the complexity of abuses in global supply chains. The Committee found that the UK's current approach, based largely on voluntary corporate reporting, fails to prevent exploitation and that goods made with forced labour are likely being imported and sold in the UK. The scale of the problem is stark. The UK imports over $26 billion worth of goods annually from five sectors at high risk of exposure to forced labour, and current approaches are failing to prevent those goods from entering the market. Cargo flights are permitted to bring goods directly from the capital of Xinjiang into the UK unhindered, and media investigations have provided evidence that products produced under forced labour conditions are actively reaching British consumers. The Committee's chair, Lord David Alton, stated plainly that a voluntary system is not going to be enough to root out wrongdoing.
The Joint Committee calls for mandatory due diligence, import bans, and new civil liability within one year.
The report's overarching recommendation is for the UK Government to strengthen existing legislation and create entirely new laws establishing corporate responsibility. Three pillars anchor the Committee's proposals. First, mandatory human rights due diligence: the report finds that the UK is not currently keeping pace with other states and should impose mandatory supply chain due diligence, with regulatory oversight and financial penalties for non-compliance proportionate to company turnover. Evidence from the business sector showed genuine willingness for mandatory due diligence, as it would create a level playing field and consistency across markets. Second, import bans: the Joint Committee reviewed the effectiveness of import bans in the EU and USA and highlighted the serious risk of the UK becoming a dumping ground for goods that cannot be sold in other markets. The report recommends introducing an import ban on goods produced using forced labour, modelled on a rebuttable presumption similar to the US Uyghur Forced Labor Prevention Act, meaning goods from certain high-risk regions would be presumed to be made with forced labour unless proven otherwise with clear and convincing evidence. Third, a new civil cause of action: the report found that it is currently too difficult for survivors of forced labour to bring cases against UK companies that have profited from their exploitation. A dedicated civil route for failure to prevent forced labour would place the burden on companies to demonstrate they had taken adequate preventive steps. The Joint Committee called on the Government to introduce legislation implementing these recommendations within one year of the report's publication.
The US and EU have moved decisively on forced labour while the UK's framework has stagnated.
One of the most striking aspects of the report is its comparative analysis. The UK's reporting regime under the Modern Slavery Act is now out of step with many comparable jurisdictions on supply chain transparency and due diligence. In the United States, the Uyghur Forced Labor Prevention Act creates a rebuttable presumption that goods produced in the Xinjiang region are made with forced labour and are therefore subject to an import prohibition. In the EU, the Forced Labour Regulation entered into force in December 2024 and will prohibit products made using forced labour from being sold in or exported from the EU market, backed by the broader Corporate Sustainability Due Diligence Directive which imposes extensive mandatory due diligence obligations. In contrast, the UK's Modern Slavery Act has been criticised as having no teeth. A House of Commons committee stated as far back as 2021 that the Act is out of date and does not require businesses to conduct basic due diligence. An estimated 40% of eligible companies were not even complying with the existing reporting requirement, and there had been no attempts at enforcement. The new report makes clear that without urgent reforms, the UK risks becoming an attractive destination for goods that cannot be sold in the US or EU — effectively absorbing the forced labour problem from other markets.
Proactive supply chain due diligence is no longer optional — it is the direction of regulatory travel.
Whether or not the UK Government moves swiftly to legislate, the direction of travel is unmistakable. The Government has already acknowledged the need for stronger enforcement mechanisms and proportionate penalties for non-compliance, and has committed to consulting on mandatory due diligence requirements. The Procurement Act, which came into force in February 2025, also strengthened the exclusion regime for modern slavery to prevent exploitative companies from securing government contracts. For businesses, the practical implication is clear: those who wait for legislation to force their hand will be caught flat-footed. Organisations should consider undertaking supply chain due diligence exercises and updating internal policies now, anticipating the anticipated mandatory duties. This means mapping supply chains beyond tier-one suppliers, engaging suppliers with structured questionnaires, conducting risk assessments for high-risk geographies and commodities, and building governance mechanisms to ensure board-level accountability. Tools like FRDM's supply chain risk platform allow companies to move from reactive compliance to proactive oversight — using spend data to build dynamic risk maps, monitor supplier exposure, and generate modern slavery statements that reflect genuine action rather than mere box-ticking. As global regulatory pressure intensifies from multiple directions — EU, US, Canada, and now an increasingly serious UK posture — supply chain transparency is fast becoming a baseline expectation, not a differentiator.
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