Articles

Risk Radar | September 2026

By Nathan Peacey, Tamzin Robson, Edward Bell, Sophie Chong, Matteo Hassan

4 Sep 2026 | 4 minute read

Compliance

Government proposes tougher modern slavery reporting rules

The Government's Immigration and Asylum Bill, proposes reforms to the reporting regime under section 54 of the Modern Slavery Act 2015. The changes include mandatory reporting requirements, a director-signed accuracy statement and financial penalties for non-compliance. The Bill is currently progressing through Parliament.

Martyn's Law notification requirements published

The Government has published regulations setting out the notification requirements under Martyn's Law, ahead of the expected commencement of the Terrorism (Protection of Premises) Act 2025 in April 2027. The regulations outline how and when responsible persons must notify the Security Industry Authority and update information where circumstances change. Retailers with premises that may fall within scope should begin preparing for the new requirements.

Employment Rights Act 2025 update

Further reforms under the Employment Rights Act 2025 are due to come into force in October 2026. These include new obligations on employers to take all reasonable steps to prevent harassment, potential liability for third-party harassment, increased trade union rights and longer employment tribunal time limits. Retailers should ensure they are prepared for these changes. See our guidance here.

Data

Data protection complaints regulations now in force

The Data (Use and Access) Act 2025 rules that businesses must follow when handling data protection complaints are now in force. Businesses will need to operate compliant complaints procedures and ensure that data rights concerns are managed consistently and in line with ICO expectations. See the ICO's article here and guidance on the rules here.

ICO publishes smart appliances guidance

The ICO has published final guidance for smart appliance manufacturers on collecting customer data and displaying targeted adverts. Any retailers that produce and sell their own smart appliances should review the guidance and ensure that they are compliant. The full guidance can be found here.

Marketing updates

Subscription contract rules to come into force from January 2027

Following a recent announcement from Andy Burnham, the new subscription contract provisions under the Digital Markets, Competition and Consumers Act 2024 will come into force from January 2027. The rules introduce new requirements for businesses offering subscription arrangements, including obligations relating to consumer information, renewal reminders and cancellation rights. Businesses operating subscription models should ensure preparation for implementation is underway.

EU greenwashing rules take effect from September 2026

New EU rules designed to combat greenwashing will apply from 27 September 2026. The measures introduce restrictions on generic environmental claims and certain sustainability labels, with the aim of improving transparency and consumer protection. Retailers selling products in the EU should review environmental claims and marketing materials ahead of implementation.

CMA launches three further drip pricing investigations under the DMCCA

The CMA launched three further investigations under the consumer protection provisions of the Digital Markets, Competition and Consumers Act 2024 (DMCCA), focusing on alleged 'drip pricing' practices by Trainline, Virgin Atlantic and RED Driving School. The investigations concern whether mandatory fees, taxes or charges were excluded from upfront prices and only disclosed later in the purchasing process. Retailers should review customer pricing journeys to ensure mandatory charges are clearly disclosed from the outset.

ASA publishes report examining environmental claims

The Advertising Standards Authority (ASA) has published a report on the use of environmental claims in UK online advertising. The report highlights the need for robust substantiation of claims such as "eco-friendly", "sustainable" and "carbon neutral". The Committee of Advertising Practice (CAP) intends to publish further guidance for advertisers on environmental claims.

Sanctions and trade

OFSI publishes sanctions ownership and control update

OFSI has published insights from its consultation on the challenges in applying the legal test contained in UK financial sanctions regulations to determine whether a business or asset is owned or controlled by a sanctioned person (such that the relevant business or asset must also be treated as being sanctioned). OFSI says the responses highlighted the practical challenges for businesses in assessing ownership and control in Russian related business in particular. While OFSI has acknowledged data provided on the significant additional cost of conducting diligence on who actually controls a business, the relevant legal test remains under review and OFSI has for now, declined to endorse any of the tools or legal concepts detailed by respondents for assessing control, instead referring back to existing OFSI guidance.

OTSI publishes 2025/26 annual review and Russia sanctions evasions guidance

In its 2025/26 annual review, the Office of Trade Sanctions Implementation reported that it has not yet imposed any civil monetary penalties but has referred 40 of the 104 enforcement cases it closed to HMRC (which has criminal enforcement powers and is the relevant agency for breaches of trade sanctions which predate the formation of OTSI). In the guidance on Russia sanctions evasion, OTSI highlights particular goods including several less commonly associated with defence activity such as printing inks and computer monitors which are at heightened risk of being diverted to Russia and recommends enhanced diligence on customers based in Armenia, China, India, Israel, Kazakhstan, Kyrgyzstan, Malaysia, Serbia, Thailand, Turkey, UAE, Uzbekistan and Vietnam.