UK Moves from Reporting to Mandatory Human Rights Due Diligence: Why a £350m Threshold Reaches Every Supplier
The UK has announced mandatory human rights due diligence for large businesses and a forced-labour withdrawal power. The obligation lands on buyers; the evidence requests land on their suppliers.
The conclusion first: the UK is moving from asking large companies to report on modern slavery to requiring them to act on it. The threshold catches only the largest buyers. The evidence requests will not stop there.
What was announced
On 4 November 2026 the UK government said it will legislate for mandatory human rights due diligence.
Why this is a different kind of obligation
Section 54 of the Modern Slavery Act 2015 requires companies above £36m turnover to publish a statement. A statement that says “we took no steps” is compliant. The announced regime replaces disclosure with a duty to act, and attaches a product-withdrawal power to it. That is the shift from “tell us what you did” to “show us the risk assessment and what changed because of it”.
Why a £350m threshold reaches you
Most of this week’s coverage treats the threshold as a scope limit. Read it from the buyer’s side and it is the opposite. A buyer cannot assess labour risk in a supply chain it cannot see, so the first act of due diligence is a questionnaire to every tier-one supplier, and the second is a request to go further upstream.
For a rubber, cocoa or coffee supplier, the questions arrive before the law does: which farms, which workers, what labour arrangements, and what evidence sits behind the answer. A supplier who can name the farm, the collector and the processing site answers in a day. A supplier who cannot becomes the risk the buyer is obliged to address.
The question to ask this week
If a UK buyer asked tomorrow who works across your supply base, what could you show them?
Agridence maps supply bases to farm and collection-point level across natural rubber, cocoa and coffee, so the chain a buyer will ask about already exists as data. If you want to compare notes on what that evidence looks like, book a short call: Book a demo
Sources
UK Government announcement on mandatory human rights due diligence, 4 November 2026 [TO CONFIRM: add the official source URL]
Modern Slavery Act 2015, section 54
Regulation (EU) 2024/3015 on prohibiting products made with forced labour, EUR-Lex
OECD Guidelines for Multinational Enterprises (2023 update); UN Guiding Principles on Business and Human Rights