No human-rights due-diligence standard in public technology procurement

The Procurement Act 2023, in force since 24 February 2025, permits exclusion of suppliers only on defined grounds: Schedule 6 turns on convictions or a threat to national security, Schedule 7 on labour-market, environmental and professional misconduct. Nothing in the Act, the National Procurement Policy Statement or any Procurement Policy Note requires a contracting authority to assess a technology supplier's human-rights record, or the dual-use surveillance potential of its products, before award. The modern-slavery instruments (PPN 009 and section 54 of the Modern Slavery Act 2015) are confined to slavery, forced labour and trafficking in supply chains, and section 54 makes due-diligence disclosure optional. The central debarment list remained blank in its most recent published version, and the government's October 2025 response to the Joint Committee on Human Rights made no commitment to mandatory due diligence. Surfaced by The Synthetic State (syntheticstate.netlify.app), a pseudonymous self-published investigation; the underlying facts here are cited to primary sources, not to that synthesis.

Public procurement is the state's largest commercial lever, and the UK's National Action Plan on the UN Guiding Principles (last updated May 2016) already commits the government to reflecting human rights in public purchasing, yet that commitment has never been turned into a method or a duty. Technology contracts raise risks the modern-slavery regime cannot see, because the harm can sit in what a product does rather than in how it was made. Without a shared standard, individual authorities have no defensible way to ask the question, and the exclusion powers Parliament created sit unused.

A published human-rights due-diligence standard for technology procurement: a model questionnaire, risk framework and evidence base aligned with the UN Guiding Principles and OECD guidance, drafted openly so contracting authorities can adopt it voluntarily as conditions of participation within the existing Act. Pilot it with willing authorities, track use of the exclusion and debarment powers, then press for adoption as a Procurement Policy Note or through the Responsible Business Conduct review.

// Build together: The standard and monitoring can be built now by researchers and civil society; individual authorities can adopt it voluntarily within the Act's flexibilities. Making it a requirement needs the Cabinet Office.

A live policy window: the Responsible Business Conduct review and section 54 amendments are in progress, and the standard is draftable now with a concrete lever.