Commercially Connected shorts - 22 October 2025

This week we look at:

• UK Government response to report into forced labour in international supply chains
• global Sustainability & ESG Insights - August & September 2025
• UK DRCF reports on AI and Digital Hub pilot and launches call for views on agentic AI
• Updata: your quarterly data privacy and cybersecurity update

UK Government response to report into forced labour in international supply chains 

On 16 October 2025 the UK Government’s response to the UK Joint Committee on Human Rights’ July 2025 report on its inquiry into forced labour in international supply chains was published.

The report recommended sweeping reforms to the current legal framework, including strengthening the reporting duty in Section 54 of the Modern Slavery Act 2015 (MSA) and introducing new legislation to establish mandatory human rights due diligence, an import ban on goods linked to forced labour, and a “duty to prevent” imposing civil liability on businesses that don’t take adequate steps to prevent forced labour in their supply chains.

The Government response refers throughout to its ongoing review into the UK’s approach to responsible business conduct, which forms part of its Trade Strategy and is focused on UK businesses’ global supply chains. Concrete decisions on policy options and legislative proposals are postponed pending the outcome of this review.

Of particular note are the following points from the response:

• The Government notes that it is considering how to strengthen the Section 54 MSA regime, including reporting requirements, turnover threshold, penalties for non-compliance and application to public bodies, but that “significant long-term reform will take time”. It also refers to the Transparency in Supply Chains statutory guidance which calls on businesses to go beyond the requirements of the MSA in their pursuit of eliminating modern slavery from their supply chains.
• The Foreign, Commonwealth and Development Office is undertaking a National Baseline Assessment on implementation of the UN Guiding Principles on Business and Human Rights, and the results of this will be taken into account in informing UK approach to dealing with human rights abuses in global supply chains.
• The Office for Responsible Business Conduct has recently been established and is responsible for tackling supply chain harms including forced labour.
• The Government says that “We remain committed to ensuring that any future arrangements are coherent, efficient, and capable of delivering meaningful impact.”
• A Critical Minerals Strategy is expected later this year, which will “refine our approach to responsible and transparent supply chains”.

Reform and extension of the current MSA regime has been on the cards for some time, but this response doesn’t bring that reform any closer. Businesses will need to wait for the outcome of the review of the UK’s approach to responsible business conduct for a clearer indication of what changes the Government is considering and when these might come into force.

Global Sustainability & ESG Insights - August & September 2025

Welcome to the latest edition of our monthly Global Sustainability & ESG Insights providing you with a summary of the key developments from around the world.

This edition includes:

• Global Reporting Initiative announces development of new pollution standards
• EU Carbon Border Adjustment Mechanism
• EU Waste Framework Directive
• EU Deforestation Regulation delayed
• EU Regulation to reduce microplastic pollution
• UK key sustainability disclosure consultations close
• UK draft Environmental Protection (Wet Wipes Containing Plastic) Regulations published
• Welsh Government consults on future drinks container deposit return scheme

UK DRCF reports on AI and Digital Hub pilot and launches call for views on agentic AI

On 10 October 2025 the Digital Regulation Cooperation Forum (DRCF) published a report on the effectiveness of its AI and Digital Hub pilot (Hub).

The DRCF is a collaboration between the CMA, ICO, Ofcom and FCA, the key UK digital regulators. Its mission is to “support responsible technological innovation, protect people online, and enable businesses to thrive”.

During the one year pilot project, the Hub gave free, informal, cross-regulatory advice to organisations developing tech that has a public or societal benefit. The aims of the pilot were to help development of digital tech through enhanced clarity on regulatory compliance, as well as to help assess whether a permanent multi-regulator service should be established.

The report concludes that the pilot was a success, whilst noting improvements for the future.

The DRCF now intends to expand the Hub’s reach and impact by launching a Thematic Innovation Hub. It describes this as “a cross-cutting initiative, enabling businesses to benefit from joined-up regulatory insight on emerging technologies” which will “extend the DRCF’s reach through tailored engagement and regulatory advice on priority topics”.

The first theme that the DRCF will focus on is agentic AI, which it defines as “AI systems capable of autonomous decision-making and initiating actions without direct human prompts”.

On 10 October 2025 it opened a call for views on agentic AI and regulatory challenges. This is an information-gathering exercise to help inform future work and to enhance understanding of emerging risks and opportunities.

Views are sought on issues such as the interplay between regulation and successful development and adoption of agentic AI, any sector-specific issues, risks and opportunities, and what advice and support would be beneficial.

Responses are due by 6 November 2025 and any organisations working (or considering working) with agentic AI may wish to respond.

Updata: your quarterly data privacy and cybersecurity update

Welcome to the latest edition of Updata – the international update from Eversheds Sutherland’s Data Privacy and Cybersecurity team. Updata provides you with a compilation of data, privacy, AI and cybersecurity regulatory and legal developments from our contributors around the globe over the past quarter, including:

• artificial intelligence - new EU AI Act transparency guidelines, final GPAI Code of Practice, California’s Transparency in Frontier AI Act, and national AI laws in Italy
• smart data laws – EU Data Act implementation, EDPB guidance on data sharing, and the UK’s Data (Use and Access) Act 2025
• data security and cybersecurity - increased regulatory scrutiny, new incident reporting in Italy, China, and Hong Kong, major fines in Italy and Spain, and the UK’s proposed ransomware payment ban
• data sharing - Dutch and US cases on disclosure of data sharing practices and sensitive health data
• children and data - EU age verification app, guidance on CCTV in schools, and new standards for minors’ data in China and the UK
• health and biometrics - new US state laws, German and Portuguese guidance, and regulatory focus in Italy, the Netherlands, and the UK
• regional updates - legal changes across Europe, Asia Pacific, Africa, the Middle East, and the US
• case law and guidance - ECJ on pseudonymous data, EU-US Data Privacy Framework, GDPR right of access, and use of CCTV and biometrics
• cybersecurity regulation - progress on NIS2, ENISA technical guidance, and UK-France partnership on critical infrastructure
• consultations - ongoing reviews of the Digital Markets Act, Digital Services Act, and Chips Act 2.0