Momentum builds for stronger UK legislation to protect against human rights and environmental harms in UK value chains
The IASC has today (16 December 2025) published a proposal for a new mandatory human rights due diligence law. Whilst this proposal contains useful elements, it falls short of the comprehensive measures being developed and championed by the CJC since 2017, which are urgently needed to align with international standards and address interconnected human rights and environmental harms in UK supply chains.
Download the full statement here.
In November 2023, Baroness Young of Hornsey introduced into the House of Lords a proposal for a new UK law, supported by this Coalition – Commercial Organisations and Public Authorities Duty (Human Rights and Environment) Bill. If passed, this bill would have introduced an obligation for companies to conduct human rights and environmental due diligence and clear penalties for those that failed to take reasonable steps to prevent human rights or environmental harms.
Throughout 2025, we have seen growing calls for this type of legislation from a diverse group of stakeholders. Support now includes aligned statements from the Joint Committee on Human Rights, the Business and Trade Committee, the Ethical Trading Initiative, parliamentarians, trade unions, businesses and investors, 145,000 signatories of a public petition and of course, from affected rightsholders themselves.
This week, the Independent Anti-slavery Commissioner added her support to this movement with the release of a new report outlining why stronger legislation is needed, including a proposal for a mandatory human rights due diligence law, drafted in partnership with UNSEEN, Forward Global and Omnia LLP. Several aspects of this publication align closely with the legislative changes that we have been calling for over several years. In particular, the commissioner highlights the need for a preventative approach “requiring organisations to take proactive, practical steps to steps that stop abuse at its source”. The Commissioner also recognises the importance of applying the “failure to prevent” model used in the UK Bribery Act. This mechanism reverses the burden of proof so that companies will be expected to prove that they have taken reasonable measures to prevent harm. This is an important shift from our current system whereby survivors of serious corporate human rights violations are burdened with the responsibility of proving that a certain company is responsible for those harms.
However, despite these positive recommendations and given the need to avoid a piecemeal approach to corporate accountability, we note the following key gaps in the draft legislative proposal. Our analysis focuses on ensuring alignment with international standards and ensuring that a new law is fully effective in preventing and remediating corporate harms.
Analysis of harms covered
Narrowing the scope of human rights protected.
This proposal limits corporate responsibilities only to so-called “serious” human rights harm. A definition or conceptualisation of “serious” human rights does not currently exist within international human rights law or guidelines and so the power to define what is or isn’t “serious” is being granted to the Secretary of State. When listing the relevant legislation, the draft law does not refer to the Declaration on the Rights of Indigenous Peoples, or the Right to a Clean, Healthy and Sustainable Environment. This risks creating a hierarchy of human rights abuses, potentially disregarding the indivisibility of all human rights and excluding some as not “serious” enough to warrant a response.
Exclusion of environmental harm
Particularly concerning is the exclusion of environmental harms from this draft law. Evidence is clear that environmental degradation and climate change are driving human rights abuses including modern slavery. The integration of human rights and environmental due diligence rules into one law is necessary to properly protect all human rights and ensure alignment with the approach being called for by the Ethical Trading Initiative, parliamentarians, trade unions, businesses and investors, rightsholders and human rights defenders, and the public and the approach already being taken in other countries and regions including France, Germany, South Korea and the EU.
Examples of devastating environmental harms linked to UK corporations include Shell’s oil pollution in the Niger Delta; widespread toxic PFAS pollution that could cost the UK £9.9billion a year to clean up; UK banks’ links to deforestation, land seizure, and land conversion in the Amazon; and Anglo-American’s links to lead contamination in Kabwe, Zambia. In each of these cases, it is clearly evident that corporate impacts on human rights and the environment are indivisibly linked and must be addressed in an integrated manner.
Analysis of actors covered
“Large” enterprises
The UNGPs clearly state that “the responsibility of business enterprises to respect human rights applies to all enterprises regardless of their size, sector, operational context, ownership and structures” and “some small and medium-sized enterprises can have severe human rights impacts, which will require corresponding measures regardless of their size”. This is particularly important for ensuring that any new legislation is gender responsive, as women are more likely to depend on precarious, informalised employment, including within small to medium sized enterprises. Therefore, we are concerned to see that this proposal would limit key obligations only to “large enterprises” with a turnover exceeding £36million.
As the implementation of the UK Bribery Act has already demonstrated, rather than focusing on thresholds, the new law should require proportional action from businesses of all types and sizes including ensuring that large businesses provide support to SMEs within their value chains.
Public sector bodies
Rather than limiting responsibilities to commercial organisations or public undertakings, the scope of this law must also fully include public sector bodies and public procurement processes. With a budget of over £400 billion annual spending, inclusion of the public sector is key to support responsible business conduct and ensure that tax payers money is not being spent in a way that perpetuates human rights and environmental harms.
Analysis of mechanisms proposed
As it stands, the proposal lacks specific and accessible mechanisms for rightsholders to submit claims of harm and be involved in the development of sufficient remediation with businesses and an independent regulator. The proposal further appears to narrow remediation to only certain circumstances and introduces restrictive time limits on compensation. At the same time, the proposal fails to detail the steps needed to ensure rightsholders, including women, workers, trade unions, local communities, Indigenous Peoples and marginalised communities, are sufficiently engaged to ensure preventative action before “serious” harm occurs. Finally, the proposal does not introduce an independent regulator which is necessary to protect rightsholders, ensure consistent enforcement and provide legal certainty for businesses to plan and invest into respecting human rights and the environment.
What is needed
In line with international guidance and drawing on the deep expertise of a diverse coalition of legal experts, CSOs, trade unions and affected communities, this coalition is calling for the introduction of a Business Human Rights and Environment Act, a mandatory human rights and environmental due diligence law that incorporates eight principle elements including a clear duty to prevent harm. This law would ensure alignment with international developments, act on the demands of diverse stakeholders and provide comprehensive protection to potential victims of corporate abuse and hold companies accountable if they fail to take reasonable action.
Right now, the Government is undertaking a review of its approach to Responsible Business Conduct and a National Baseline Assessment of the UK’s implementation of the UN Guiding Principles on Business and Human Rights. This is an opportunity for action. However, to ensure a meaningful outcome, these reviews must not only be transparent and listen to those most affected but must also take a cross-cutting approach in addressing all types of human rights and environmental abuses.
Therefore, considering this window of opportunity and the welcome support from the Independent Anti-Slavery Commissioner for new UK legislation, this Coalition urges the Government to:
- Heed the widespread, evidence-based and growing calls for the introduction of mandatory human rights and environmental due diligence legislation and introduce a Business Human Rights and Environment Act for the UK.
- Share comprehensive updates regarding the status and next steps for the two ongoing reviews.
- Ensure that the decision-making processes that follow these reviews prioritise solutions that will offer the best outcome not only for responsible business owners, workers and survivors of all forms of human rights abuse, but also for our shared planet.
Signed by:
ABColombia
ActionAid UK
Amnesty International UK
Antislavery International
CAFOD
Corporate Justice Coalition
Earthsight
Freedom United
Friends of the Earth
Global Witness
Labour Behind the Label
Peace Brigades International UK
Rights and Accountability in Development (RAID)
Scottish Fairtrade
Trócaire
UNISON
WaterWitness International
