Sustainability/ESG

The Joint Committee on Human Rights has published a report calling out the UK’s failure to adequately address forced labour in global supply chains. The Committee finds that current legal frameworks are not fit for purpose and urges the government to take decisive action.

Landmark climate arbitration claim against UK

We reported, in the last edition of Legal Horizon, that the International Court of Justice had delivered its Advisory Opinion on Climate Change. We anticipated the Opinion would have implications for both states and businesses, in terms of confirming climate obligations and signifying increased risk of climate-related litigation. Now, for the first time, a landmark climate arbitration claim is being brought against the UK state. The developer and an investor in West Cumbrian Mining are pursuing a claim following the quashing of a proposal for a new coal mine. WCM had been granted permission to develop the coalmine by the previous Conservative government.

The High Court subsequently blocked the project due to environmental concerns. (The High Court applied Supreme Court’s decision in Finch v Surrey County Council, which required scope 3 emissions to be assessed in the environmental impact assessment.) Labour ministers then withdrew government support for the mine and the planning application failed. The claimants argue that the revocation and related regulatory measures unlawfully interfered with their investment and denied them protections guaranteed by a relevant investment treaty. The claim shows how climate obligations and shifting policy are directly impacting states, businesses and investors; and how innovative legal approaches are developing as a result.

Deforestation-free Products Regulation

The European Commission is considering delaying the application of the Deforestation-free Products Regulation until December 2026. The Deforestation-free Products Regulation will impose mandatory supply chain due diligence requirements on companies placing relevant commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and related products on the EU market.

Corporate/corporate reporting

The FCA published its climate reporting review  containing its findings and next steps following its review into climate reporting by asset managers, life insurers and FCA-regulated pension providers.

Following the FCA’s approval of the London Stock Exchange as the first operator of a Private Intermittent Securities and Capital Exchange System (PISCES) trading venue, the London Stock Exchange (LSE) has published Market Notice N09/25, which attaches drafts of two key documents for its Private Securities Market: the Private Securities Market Rulebook and the Private Securities Market Handbook. These documents outline how the market will operate, and the LSE’s approach to non-compliance. The Private Securities Market is expected to launch late in 2025.

The FCA has published Quarterly Consultation Paper No. 49 (CP 25/24), which consults on proposed amendments to the FCA Handbook, including: amending UKLR 9.6.6R to align the timing and frequency of share buy-back notifications with the reporting deadline for the share buy-back safe harbour under Article 5 of Market Abuse Regulation; removing regulatory contactless limits; and giving proper effect to existing ESG sourcebook rules and providing flexibility for firms to publish ongoing product-level sustainability reports in alignment with other annual fund reporting requirements.

The FCA and Prudential Regulation Authority are proposing to streamline the Senior Managers and Certification Regime.

Also in FCA news, the FCA has launched its new Handbook website, which allows users to navigate the Handbook more intuitively, and facilitates quick comparisons of how the guidance has changed over time.

The Financial Reporting Council (FRC) has launched a consultation running until 16 January 2026 on revised auditing standards to strengthen fraud detection and going concern assessments, aligning UK rules with updated international standards. The changes aim to enhance transparency and oversight, with minimal additional burden expected for auditors, and will apply to audits for periods starting on or after 15 December 2026.

Financial Reporting Council launches Innovation and Improvement Hub

The FRC has launched an Innovation and Improvement Hub to foster regulatory innovation and support market growth. Early priorities include exploring AI’s impact on audit, reducing the length of annual reports, and enhancing cross-regulatory collaboration to improve oversight and support for smaller audit firms.

The FRC has published its annual review of corporate reporting for 2024/2025, which outlines the FRC’s top ten areas where improvements to reporting are required and sets out expectations for companies for the next reporting season.

Government publishes financial services strategy

The government has published its Financial Services Growth and Competitiveness Strategy setting out key areas of focus: delivering a competitive regulatory environment; harnessing the UK’s global leadership in financial services; embracing innovation and leveraging Fintech; retail investment and capital markets; and financial services skills and talent. The strategy is intended to complement the government’s broader industrial policy with the Leeds Reforms cutting red tape, supporting investment to boost growth and creating skilled jobs. The Chancellor set out the government’s commitment in her second Mansion House speech.

Remember, the new corporate criminal offence of failure to prevent fraud, designed to drive an anti-fraud culture and improve business confidence, came into effect on 1 September 2025. See our briefings for more information.

Data protection/cyber security/tech and digital

The government has published its plans for commencement of the Data (Use and Access) Act (DUAA). The DUAA will be implemented in four key stages between August 2025 and early 2026. The Information Commissioner’s Office (ICO) has launched a consultation, which closes on 30 October 2025, on its draft supporting guidance.

Guidance for handling data protection complaints

The ICO is consulting on draft changes to how it handles data protection complaints and on draft guidance for organisations handling data protection complaints.

The ICO issued new guidance on disclosing documents to the public, to help organisations understand how to check documents, including spreadsheets, for hidden personal information, and to reduce the risk of a data breach.

The Pension Administration Standards Association published data guidance providing advice on improving data security and governance in pensions administration.

Cyber Assessment Framework updates

The National Cyber Security Centre (NCSC) has rolled out a series of updates to its Cyber Assessment Framework aimed at assisting operators of Britain’s critical national infrastructure in better managing their security risk profiles. The NCSC also rolled out free online training courses to help businesses protect against cyber threats and online fraud.

Windows 10 is nearing end of life. The NCSC has provided guidance on how to prepare your organisation for Windows 11 before Autumn 2025.

Also in NCSC news, release of CAF v4.0 enhances the Cyber Assessment Framework to better support essential service providers in managing growing cyber threats through clearer guidance, improved usability, and alignment with evolving risk landscapes. See this our article  outlining essential measures businesses should implement to prepare for and respond to cyber incidents effectively and also this  our article for a debrief on the latest mitigations for ransomware attacks.

The government has said it will take forward with industry proposed measures to tackle the threat of ransomware and protect businesses and critical services.

The government has publicly identified Russian military intelligence group APT28 as responsible for deploying previously unknown malware to conduct espionage by targeting victim email accounts.

The cybersecurity insurance market is reportedly projected to double by 2030.

The government announced the formation of a new expert working group on AI and copyright, comprising representatives from the creative industries and AI sectors. In related news, the European Parliament has published a draft report and a study on copyright and generative AI.

Developments in humanoid robotics

We’ve noted previously that China is reportedly (Reuters) building and training humanoid robots at such a scale that their cost could be halved (paving the way for economic viability and wide-scale commercial use) by 2030. In related news, Amazon is using humanoids with a sense of touch in its fulfilment centres, and MIT, UCL and Cambridge University are reporting significant developments in humanoid robots both with and without artificial skin.

Another newsworthy development is Google DeepMind’s Gemini 1.5 – a vision-language-action AI-powered robotics model that can now see, process instructions, and act accordingly to carry out real world tasks such as, for example, sorting piles of laundry by colour. In the Financial Times (25 September 2025), Ingmar Posner, professor of applied artificial intelligence at the University of Oxford, said the development could help robotics reach a “ChatGPT moment”.

As part of the US President’s State Visit, the UK and US have agreed the Tech Prosperity Deal  to boost fast-growing technologies like AI, quantum, and nuclear.

A new taskforce has been launched to accelerate development of the North East’s AI Growth Zone, expected to create thousands of jobs across sectors from construction to advanced AI. Backed by universities, industry leaders, and firms, the initiative will fast-track planning, investment, and training routes, with spades in the ground within weeks as part of the government’s Plan for Change.

For further updates, please see our September Technology & Digital round-up.

Commercial/general

Hundreds of UK tech start-ups and other innovative businesses can now apply for government support to protect their intellectual property from powerful competitors, including threats from other states and hostile actors.

The Intellectual Property Enterprise Court has recently handed down several judgments demonstrating the versatility of the IPEC as a forum across a wide range of sectors. We’ve prepared a whistle stop summary of the cases and their key takeaways.

Greenwashing concerns raised by Which?

Which? has published data from a recent investigation, finding than 6 in 10 products failed checks in relation to multiple principles of the Competition and Market Authority (CMA)’s Green Claims Code. For information and advice in relation to ‘greenwashing’ and the wider ‘washing’ phenomenon, see our overview briefing.

The CMA has published guidance, ‘Competing for Talent’, to help employers understand how competition law applies to their work.

The Bank of England is consulting until 21 October 2025 on its proposal for extending the settlement hours of RT2 and CHAPS.

The FCA has outlined its Consumer Duty focus areas for 2025/26 aiming to embed the Duty across sectors to improve consumer outcomes, reduce regulatory burden, and support flexibility.

The Pensions Regulator has published a consultation open until 11 November 2025 outlining its revised enforcement policy to provide clarity and transparency about how it will exercise its powers and what regulated parties can expect during enforcement action.

Insolvency Service strategy on economic crime

The Insolvency Service launched a new 5 year investigation and enforcement strategy committing the agency to a prominent role in the fight against economic crime, with an expansion of its current remit.

Last year, the UK government announced a package of measures aimed at tackling late payment. Continuing that theme, the government has published its Small and Medium Sized Business Plan, setting out a package of proposals, including fines for businesses which fail to pay suppliers on time, restrictions on customers’ ability to withhold payment in the event of a dispute, and a new arbitration system. If implemented, the measures are likely to lead to a tougher regulatory environment, particularly for larger businesses using SME suppliers.

New guidance on consumer price transparency

The UK government has introduced new guidance to improve consumer price transparency, replacing parts of the Price Marking Order 2004 (PMO) to reflect amendments taking effect on 6 April 2026. The PMO applies to business‑to‑consumer sales of goods. Traders should update in‑store and online materials such as signage, product labels, pricing displays and promotions ahead of 6 April 2026.

As part of its 14th Programme of Law Reform, the Law Commission has launched a project to modernise the law of deeds. The review will explore whether the current framework remains fit for purpose, particularly in light of digital execution and smart contracts.

The New Towns Taskforce has published its report, with the government committing to progress a new generation of towns across England. 12 locations are proposed, with at least 3 set to break ground during this Parliament. A public consultation will follow in Spring 2026, alongside wider reforms including the Planning and Infrastructure Bill, housing programmes, and updates to national planning policy.

Construction products reform and safety guidance

We’ve reported previously on the Construction Products Reform Green Paper on wide-ranging plans for future regulation of construction products. Proposals include bringing all construction products within the general product safety regime; enhanced regulatory, surveillance and enforcement powers; development of a new single Construction Products Regulator; and civil and criminal penalties for manufacturers that engage in misleading practices or neglect their responsibilities regarding product safety.

The government has said that the paper is the first step in what will be a proactive process of engagement and consultation across the system in the medium to longer term. The Chartered Institute of Building, in collaboration with various construction industry bodies has published the Guide to Products Critical to Safe Construction – a new resource aiming to signpost best practice, raise awareness of compliance standards, and provide advice on how to determine if a product is critical to safe construction. It’s likely to be of value to businesses across the build spectrum, from product and project design and manufacture, to contracting and development/employment.

Low and zero carbon heat networks

The Green Heat Network Fund is the UK government’s flagship capital grant programme supporting the commercialisation and construction of new low and zero carbon heat networks, as well as the retrofitting and expansion of existing ones. See our briefing on the key funding mechanisms and how commercial developers can benefit.

In related news, the government has published its response to the consultation on heat network regulation, setting out a comprehensive framework to protect consumers and support the growth of low-carbon heating.

People

The Employment Rights Bill is continuing its progress through Parliament. Royal Assent is expected in November. See our recent update on the progress of the Bill, including analysis of the new proposal to ban the use of non-disclosure agreements (NDAs).

The government has announced a digital ID scheme for UK citizens and legal residents, aimed at simplifying access to government services and curbing illegal working. Digital ID will become mandatory for Right to Work checks by the end of this Parliament.

Equality and Human Rights Commission Code of Practice

The Equality and Human Rights Commission (EHRC) has shared its final updated Code of Practice on services, public functions and associations (Service Code) to the Minster for Women and Equalities. It will now be considered by the government and, following ministerial approval, will be laid before Parliament before coming into force. However, the Chair of the EHRC has reminded service providers, associations and public functions not to wait for the Service Code to be published to make changes to comply with the law. Work on the Employment Code of Practice will begin once the Services Code is complete.

The EHRC is also reviewing its guidance on separate and single-sex services and is taking regulatory action relating to access to single-sex spaces and gender self-identification. The EHRC has said that it is now writing to 19 organisations to ask them to review policies that wrongly suggest there is an automatic legal right to access single-sex spaces based on self-identification.

The organisations must provide assurances that the policies will be withdrawn and their proposed timetable for revising the policies. The EHRC will monitor compliance and consider further regulatory action, if necessary. See our briefing on the Supreme Court’s decision in For Women Scotland Ltd v The Scottish Ministers. For tailored advice, please get in touch with any of our Employment specialists.

The Chartered Institute of Personal Development published a research report exploring the current state of flexible and hybrid working practices in the UK more than a year on from the implementation of the Employment Relations (Flexible Working) Act 2023.

Paternity and shared parental leave

The government has published its response to the Women and Equalities Committee (WEC) June 2025 report on paternity and shared parental leave. The WEC recommended extending paid statutory paternity leave to 6 weeks; increasing statutory paternity pay to the same rate as statutory maternity pay for the first 6 weeks; taking measures to increase the take-up of paternity leave; reforming the paternity leave system; and addressing the lack of provision for self-employed parents, kinship carers, single-parent families and parents of multiples.

The government’s response contains few commitments other than to review those areas. In particular, it hasn’t committed to increasing statutory paternity pay and making it a day one right.