Here's what the UK's new modern slavery NHS procurement law requires
On 17 May 2026, the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 came into force. Made on 17 November 2025 under section 12ZC of the NHS Act 2006, they raise the baseline requirements for due diligence across the NHS and its suppliers.
What the law requires
Public bodies procuring goods or services for the health service in England must assess modern slavery risk before going to market — before the tender notice in a competitive procedure, or before award where competition isn't used. The duty applies at any contract value.
In-scope bodies must take reasonable, proportionate steps to address identified risks when setting contract terms and managing the contract. Every procurement is rated low, medium or high risk and frameworks must be reassessed periodically.
The duty covers central purchasing organisations, framework and dynamic-market owners, and local authorities procuring healthcare-related goods or services. A body calling off a framework relies on the framework owner's assessment, so the obligation cascades through the procurement chain.
Why this points to deep-tier mapping
DHSC's December 2023 review found that across 60% of spend on medical consumables, 21% of suppliers were high risk for modern slavery and 16% were medium risk. That risk concentrates upstream — in the sub-tiers producing raw materials and components.
For higher-risk procurements, the "reasonable steps" available include contract terms requiring suppliers to vet their own subcontractors, cascade requirements up the chain, report supply chain details, keep traceable records, and remediate incidents.
Similar to CSDDD, the obligation to map every tier of every chain is proportionate to risk. For the categories where NHS risk concentrates — consumables, gloves and PPE, textiles, electronics, surgical instruments — meeting the standard will necessitate data collection and validation beyond tier-1.
Who needs to act
NHS trusts
Integrated Care Boards
NHS England commercial teams
Central purchasing bodies and framework owners
Local authorities procuring healthcare-related goods or services
Suppliers and their sub-tier suppliers
Building an evidentiary repository
Sourcemap supports audit-ready supply chain risk assessments via verified multi-tier supply chain mapping, traceability and compliance evidence collected from the supply chain directly and stored in a secure system of record. Find out more
