The UK’s proposed Mandatory Human Rights and Environmental Due Diligence Bill—introduced in 2024 and now making its way through Parliament—has already prompted considerable debate in boardrooms and policy circles alike. Though formal enactment isn’t expected until early 2026, many companies, particularly those with annual turnovers exceeding £36 million, are starting to think seriously about what implementation might look like. Or, to be more precise, what early steps they can take now to position themselves for compliance. Because once the law is in force, there will be little room for delay.
At its core, the Bill seeks to require businesses to conduct human rights and environmental due diligence across their global operations and supply chains. This isn’t a wholly new idea, of course—the UK’s Modern Slavery Act, the French Duty of Vigilance Law, and the German LkSG have all moved in similar directions. But what’s notable here is the broader scope: environmental harms are given equal weight alongside human rights risks. And that, for many firms, opens up a fresh set of practical challenges.
One area where UK importers might begin their preparations is pilot mapping of raw material flows. There’s no need, at this stage, to attempt a full-scale trace of every input across every product line—though some may be tempted, that risks overwhelming teams before frameworks are even established. A more pragmatic starting point could involve selecting a handful of high-risk materials, or key product categories, and mapping their flows using publicly available import/export records. HMRC trade data is one such source. It isn’t perfect—the granularity can be limited, and matching customs data to specific suppliers or shipments takes care—but it offers a useful baseline. Some firms have also looked to UN Comtrade or similar databases to supplement national records where gaps exist.
Where this gets tricky, perhaps, is the reconciliation of these official records with internal procurement data. Discrepancies are common. For instance, a company’s ERP system may list supplier details that don’t line up neatly with customs declarations. Resolving these gaps can be painstaking. But the exercise itself often yields insights: unusual patterns, concentration risks, or simply greater awareness of where data quality needs to improve before reporting obligations kick in.
Beyond mapping, firms will want to think about validation. After all, identifying where raw materials are coming from is only one part of the puzzle. Verifying conditions at source—especially where human rights or environmental risks are most acute—is another. Here, collaboration with environment-focused NGOs could prove invaluable. A number of NGOs now offer partnerships or advisory services aimed specifically at helping companies leverage open satellite imagery for supply chain monitoring. This imagery, drawn from publicly available sources like Copernicus or Landsat, can help flag potential deforestation, illegal mining, or other environmental harms linked to supplier operations.
It sounds straightforward on paper—compare supplier-provided data with satellite evidence, and, where there’s a mismatch, dig deeper. But in reality, interpreting satellite imagery requires expertise. A cleared area of land might indicate illegal activity, or it might reflect permitted development. Seasonal changes can confuse matters. And of course, cloud cover, resolution limitations, and data timeliness all complicate the picture. Some companies have found it useful to work with NGOs that offer not just raw imagery but analytical overlays—essentially, ready-made assessments that highlight anomalies or risk areas based on pre-set criteria.
Embedding these processes into existing procurement and compliance functions is, frankly, where many firms may struggle in the early stages. Mapping material flows, engaging with NGOs, interpreting data—all of this requires time, skills, and in some cases, investment in new systems or training. It may be tempting to treat these early pilots as one-off exercises, but there’s real value in designing them with scalability in mind. If a firm can build a modular approach now—one that can later be expanded as requirements become clearer—they’ll be in a stronger position when statutory deadlines approach. Or at least that’s the hope.
A further consideration, and one that perhaps doesn’t get discussed enough, is internal alignment. Compliance teams might take the lead on due diligence initiatives, but procurement, legal, sustainability, and even finance functions will need to play their parts. For example, raw material mapping often requires access to supplier contracts and shipment records that sit outside compliance’s usual purview. Similarly, collaboration with NGOs on satellite monitoring can raise questions about confidentiality, data sharing, or even liability, all of which may need careful legal input. These are not insurmountable issues, of course. But they do mean that early implementation work often reveals as much about internal processes and relationships as about external supply chains.
What remains unclear—at least at this point—is how regulators will assess company efforts once the Bill is enacted. Will firms be judged primarily on the robustness of their processes, or on the specific outcomes they achieve? Will public reporting requirements encourage genuine transparency, or will boilerplate statements proliferate, as has sometimes happened under other regimes? These are questions that many in the business community are asking, though definitive answers will probably only emerge over time.