NHS Suppliers - New Slavery Regulations

The National Health Service (NHS) supply chain spans huge volumes of goods and services, which creates potential exposure to worker exploitation, forced labour or human trafficking.

​The NHS Procurement, Slavery and Human Trafficking Regulations 2025 (The Regulations) is the NHS' response to the estimated 21% of medical consumables suppliers who are classed as high-risk for modern slavery, and 16% medium-risk. 

What NHS Suppliers Need To Know

The NHS Procurement, Slavery and Human Trafficking Regulations 2025 apply to any public body in England that procures goods and/or services for the NHS.

​This includes NHS organisations, local authorities (in their public-health or Section 75 roles), purchasing bodies and so on. Works contracts fall outside of the scope of the Regulations. 
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The Regulations will apply to new procurement activities (not existing contracts), and will follow a risk-based approach.  Procurement activities will be categorised as low, medium or high risk and NHS Procurement will take reasonable steps dependent on the level of risk. 

For each relevant procurement contract or framework, a risk assessment must be completed before proceeding (e.g., before inviting bids) using a consistent methodology. 

​The risk assessment looks at factors such as:

• the industry type
• workforce characteristics
• supplier location
• supply-chain model
• commodity type
• operational context.

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Once the risk level is determined (low/medium/high), NHS Procurment must apply the “reasonable steps” appropriate to that risk level. ​​

What This All Means For NHS Suppliers 

The Introduction of standardised, mandatory risk-assessments across the health system, will shift the NHS procurement culture from a “tick-box” exercise to an ongoing assessment.

Every procurement will be assessed for the risk of modern slavery in its supply chain:
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• Low-risk procurements will include modern-slavery clauses in the terms and conditions and allow for variation if the risk changes. 

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• Medium/high-risk procurement processes will include pre-market engagement, explicit modern-slavery risk criteria, industry-relevant standards, or a requirement to complete the Modern Slavery Assessment Tool (MSAT) within a set timeframe.

NHS Procurement can also use the Social Value Model, specifically Model Award Criterion 1e (‘Identifying and managing the risks of modern slavery’) when evaluating bids. 

​NHS Contracts can contain Key Performance Indicators (KPIs) that require NHS Suppliers to report on the steps they are taking to ensure their is no modern slavery in their supply chains. 

How NHS Procurement Will Implement This

The NHS Procurement, Slavery and Human Trafficking Regulations 2025 were laid before Parliament on 9 September 2025. Government guidance states the aim is for them to take effect in 2026.

2026 will bring greater expectations of transparency, due diligence and continual improvement to NHS supply chains. ​NHS Procurement will review upcoming/new procurements in 2026 to identify where modern-slavery risk assessments are needed.

Modern slavery clauses, KPIs, MSAT requirements and social-value criteria will be included into new NHS tenders in 2026.

NHS Procurement processes for ongoing contract-management, risk reassessment and incident responses (to spot, assess and act on any modern-slavery risks) will be communicated with NHS Suppliers. 

​For each new framework agreement, dynamic markets and catalogue-based procurement, the NHS Procurement owner will be responsible for risk assessments and ongoing reviews.

For example: an NHS Procurement framework owner should reassess risk at least every 2 years, publish the date of the latest assessment, and ensure the framework buying guides clearly set out the relevant modern-slavery mitigation steps. 
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A contracting authority calling off from an NHS framework agreement must check that the required assessment has been done and apply the reasonable steps as laid out in the NHS framework buying guides. 

​If the risk level increases (for instance from medium to high), then more intensive mitigation steps must follow — e.g., MSAT, supply-chain mapping, increased meeting frequency with suppliers. 

How Can NHS Suppliers Prepare For The Changes

• Familiarise yourself with the new Regulations. 
• Assess your supply chains for modern slavery risk. 
• Update your risk register with action taken to mitigate risks. 
• Keep your modern slavery statement up to date. 

About The Author

Naomi Clews

Naomi Clews is a NHS Procurement Consultant and owner of Naomi Clews Consultancy Limited. Naomi has over 20 years of NHS procurement experience. Find out more here.