Modern slavery is often difficult to identify, but the risks exist across many sectors and supply chains, including healthcare. Procurement teams are increasingly expected to understand those risks and take reasonable and proportionate steps to address them.
The introduction of the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 marks an important shift for NHS procurement. Alongside existing requirements under the Modern Slavery Act 2015 and PPN 009, the new regulations place clearer expectations on public bodies to actively assess and manage modern slavery risk throughout the procurement lifecycle.
It’s important to note that the regulations and PPN 009 apply to ‘public bodies’ and ‘in-scope organisations’ procuring for NHS purposes, rather than only to NHS Trusts directly. This can include central purchasing bodies, framework providers, local authorities procuring healthcare-related services, and any organisation whose procurement activity may ultimately be used by the NHS.
In practice, this means the expectations around identifying and managing modern slavery risk may extend beyond traditional procurement responsibility, particularly where frameworks or procurement routes may be used by NHS organisations.
The regulations come into force on 17 May 2026.
What do the new regulations require?
Public bodies procuring goods or services for the purposes of the health service in England must now formally assess modern slavery risk before advertising or awarding procurements. The updated NHS England guidance makes it clear that this applies regardless of procurement value and extends across the full commercial lifecycle, including framework development and contract management activity.
This includes:
- assessing the level of risk linked to the procurement,
- taking proportionate and reasonable steps to address identified risks,
- considering modern slavery during procurement design and contract management,
- reassessing risk where circumstances change, and
- keeping clear records of decisions and actions taken.
The regulations also apply to frameworks and dynamic markets, meaning that risk can’t just be assessed once and forgotten about. Framework owners will need to review and reassess risks periodically throughout the life of the agreement.
The updated guidance also makes clear that there is no such thing as ‘no risk’ of modern slavery. Instead, procurements should be assessed as low, medium or high risk, with reasonable steps applied proportionately to the level of identified risk.
What does this mean for procurement teams?
For procurement professionals, this is likely to mean changes to governance, procurement planning and documentation.
Organisations are already introducing:
- formal modern slavery risk assessments during procurement planning,
- standardised approaches to identifying low, medium and high-risk procurements,
- greater involvement from sustainability or social value teams,
- stronger supply chain due diligence requirements, and
- clearer audit trails for procurement decisions.
Procurement teams will also need to become more confident in understanding where risks are most likely to occur. PPN 009 identifies several sectors that are commonly considered higher risk, including construction, electronics, textiles, logistics, facilities management, healthcare and social care.
The expectation is not that procurement teams become investigators, but that they can identify risk indicators, ask proportionate questions and respond appropriately where concerns arise.
Framework management will also become more important. Procurement teams responsible for frameworks will need to ensure that:
- framework-level risk assessments are completed and reviewed,
- buyers understand what has already been addressed at framework level through the Buyer’s Guide, and
- call-off guidance clearly explains any additional steps contracting authorities should take.
What does this mean for suppliers?
For suppliers, the direction of travel is clear: organisations bidding for NHS and public sector contracts should expect more scrutiny around modern slavery risk and supply chain management.
This does not necessarily mean lengthy or complex processes for every procurement. The guidance repeatedly emphasises proportionality, particularly for SMEs and VCSEs. However, suppliers should expect buyers to ask more questions where risks are higher.
Depending on the procurement, suppliers may be asked to:
- explain how they identify and manage modern slavery risk,
- provide a modern slavery statement or equivalent policies,
- complete the Modern Slavery Assessment Tool (MSAT),
- provide information about supply chains and subcontractors,
- explain recruitment and labour management practices, or
- demonstrate how risks are monitored during contract delivery.
For suppliers, preparation will become increasingly important. Organisations should ensure they:
- understand their own supply chains,
- know where higher risks may exist,
- have appropriate policies and reporting arrangements in place,
- train relevant staff, and
- can explain the practical steps they are taking to reduce risk.
This is particularly relevant for suppliers operating in sectors known to carry elevated labour exploitation risks.
A shift towards ongoing contract management
One of the biggest changes is that modern slavery is no longer being viewed purely as a procurement-stage issue.
The regulations and guidance place significant emphasis on ongoing monitoring, reassessment and supplier engagement throughout the life of a contract or framework.
This means organisations will need to move beyond simply collecting policies at tender stage and instead focus more on:
- supplier relationships,
- contract management,
- escalation processes,
- corrective actions, and
- continuous improvement.
The updated guidance also places greater emphasis on reassessment throughout the life of frameworks and contracts. Where risks change, market conditions shift, or concerns arise, organisations are expected to review existing assessments and respond accordingly.
The guidance also makes clear that contract termination should usually be a last resort. In many cases, the focus should be on identifying issues early, working openly with suppliers and improving practices where possible.
Final thoughts
The new NHS modern slavery regulations don’t create an expectation of perfection. They create an expectation that risks are properly considered, decisions are documented, and reasonable steps are taken.
For procurement teams, this is likely to mean stronger governance, clearer audit trails and more structured procurement processes.
For suppliers, it means being able to demonstrate a clearer understanding of their workforce, supply chain risks and the practical steps they are taking to manage them.
Most importantly, it reinforces the role procurement can play in reducing harm and improving transparency across supply chains connected to the NHS.
How the Hub can help
If you have questions about modern slavery requirements in relation to Hub frameworks or procurements, contact the team at [email protected].