By: Maria Luiza Simplicio e Pedro Rezende<\/p>\n
The responsible business conduct agenda in the United Kingdom has just taken a significant step forward. On 4 November 2026, the UK Government confirmed, through a ministerial statement to Parliament, that it will introduce a mandatory human rights due diligence regime for large businesses, together with new powers to withdraw goods made with forced labour from the market.<\/p>\n
The announcement follows the Government’s Responsible Business Conduct Review, which concluded that the UK’s approach to preventing forced labour was fragmented and reliant on voluntary action and corporate reporting. The measure also responds to long-standing calls for reform, such as the Private Member’s Bill introduced in 2023 and the 2025 report of the Joint Committee on Human Rights on forced labour in UK supply chains.<\/p>\n
This marks a shift in paradigm. The Modern Slavery Act 2015, regarded as pioneering at the time, essentially requires businesses to report on the measures they take to combat modern slavery. The new regime, by contrast, has been designed as a duty to act: to identify, assess and address risks, rather than merely describe them.<\/p>\n
The new obligations will apply to UK businesses with global turnover above \u00a3350 million and to non-UK businesses with UK-generated turnover above the same threshold. This extraterritorial reach deserves attention, given that Brazilian groups with significant revenues in the UK market may be directly caught, even if they are not headquartered in the country.<\/p>\n
In-scope businesses will be required to identify, assess and address risks of human rights abuses and labour exploitation in their own operations and across their supply chains. The Government has described the regime as risk-based, prioritising concrete action over unnecessary paperwork, and aligned with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Responsible Business Conduct.<\/p>\n
The regime will cover services provided across the United Kingdom and goods placed on the market in Great Britain (England, Scotland and Wales). The Government also intends to set up a centralised responsible business conduct guidance hub on GOV.UK to help businesses comply with the new obligations.<\/p>\n
From an enforcement perspective, the main development is that a regulator will be empowered to investigate businesses suspected of placing goods made with forced labour on the market and to direct their withdrawal. This power, however, depends on two cumulative conditions: forced labour must be identified, and the business must have failed to meet its due diligence obligations.<\/p>\n
This design differs from the one adopted by the European Union. The EU Forced Labour Regulation prohibits products made with forced labour from being placed on the market regardless of whether the business has carried out due diligence. Under the UK model, therefore, a robust and well-documented due diligence process is likely to serve as a central element of a business’s defence.<\/p>\n
Although the details will depend on the legislative text, there are clear signs of alignment with the EU Corporate Sustainability Due Diligence Directive (CSDDD) and with the EU Forced Labour Regulation. Businesses that have already been building processes in preparation for the EU rules should be able to leverage that work and avoid duplication of effort.<\/p>\n
It is worth noting that the CSDDD itself has undergone significant revision. The Omnibus I package, published in February 2026 as Directive (EU) 2026\/470, narrowed the scope of the Directive, removed the harmonised EU-wide civil liability regime and set a single application date of 26 July 2029. The UK announcement therefore comes at a time when the European Union has relaxed its requirements, reinforcing the perception that human rights due diligence continues to consolidate as an international regulatory standard.<\/p>\n
There is, however, an important difference: unlike the CSDDD, the UK regime as announced does not cover environmental impacts. It is also unclear how the new obligations will interact with the due diligence rules on forest risk commodities and wood products announced by the UK Government earlier this year.<\/p>\n
For now, the announcement sets out only the broad framework of the regime. The Government has stated that it will work with stakeholders on the design and implementation of the rules and will introduce the legislation as soon as parliamentary time allows.<\/p>\n
A number of points remain open, including the date of entry into force and any transitional periods, the detailed content of the obligations, the identity of the regulator and the extent of its investigatory and enforcement powers, the relationship with the Modern Slavery Act, which may be superseded by or coexist with the new regime, and the consequences of non-compliance beyond the withdrawal of goods from the market.<\/p>\n
The effects of the new regime will not be limited to the businesses directly in scope. From this perspective, three groups deserve particular attention. The first comprises UK and non-UK businesses that exceed the \u00a3350 million threshold. They will need to review their policies, map risks across their supply chains and put in place prevention, mitigation and remediation mechanisms consistent with UN and OECD standards.<\/p>\n
The second, and possibly the largest, comprises suppliers. Businesses further upstream in the supply chain, even if outside the direct scope of the law, are likely to receive information requests, questionnaires and due diligence assessments from their customers. This is the case for Brazilian exporters that supply the UK market, directly or indirectly, particularly in sectors with greater exposure to labour risks.<\/p>\n
The third comprises Brazilian groups with significant operations or revenues in the United Kingdom, which may be directly subject to the regime under the UK turnover criterion, in addition to potentially being subject to the EU rules.<\/p>\n
For all of them, the recommendation is not to wait for the final text. Businesses can already assess their exposure to the new regime, map human rights risks in their operations and supply chains, review contractual clauses with suppliers and document their existing due diligence processes, including those developed to comply with the EU rules. For Brazilian businesses, this effort ties in with familiar controls, such as screening suppliers against Brazil’s Register of Employers that have subjected workers to conditions analogous to slavery, and integrity clauses in contracts.<\/p>\n
In practice, the UK announcement confirms that human rights due diligence is ceasing to be a voluntary good practice and is becoming established as a legal obligation and a condition for market access.<\/p>\n","protected":false},"excerpt":{"rendered":"
By: Maria Luiza Simplicio e Pedro Rezende The responsible business conduct agenda in the United Kingdom has just taken a significant step forward. On 4 November 2026, the UK Government confirmed, through a ministerial statement to Parliament, that it will introduce a mandatory human rights due diligence regime for large businesses, together with new powers […]<\/p>\n","protected":false},"author":15,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"inline_featured_image":false,"footnotes":""},"categories":[120],"tags":[],"acf":[],"yoast_head":"\n