ArentFox Schiff Releases 2026 Forced Labor Law Report to Guide Global Businesses Amid Anticipated Resurgence in Enforcement Activity

The report, “Navigating the Complexities of Forced Labor Laws: ArentFox Schiff’s 2026 Guide for Global Businesses,” provides a comprehensive overview of forced labor enforcement trends thus far in the second Trump Administration and predictions for what’s to come in 2026.

Based on an in-depth review of forced labor enforcement trends and proprietary analysis from the firm’s Customs Practice and Forced Labor Task Force, the Guide provides original and practical insights for global businesses on the evolving landscape for forced labor compliance.

Key takeaways include: 

• Expect a focus on enforcement to return — with potentially significant impacts on the private sector. Though the Uyghur Forced Labor Prevention Act and general forced labor enforcement slowed in 2025 amid other trade priorities, this year may be poised to bring a resurgence of forced labor enforcement activity. At the same time, litigation, shareholder activism, buyer scrutiny, and reputational impacts continue to add new risk dimensions for companies whose supply chains touch high-risk regions or commodities
• New industries and geographies will be put under the microscope. Regulators will likely continue to focus on automotive manufacturers, the electronics industry, batteries, solar, apparel and textiles, critical minerals supply chains, and steel and aluminum processors. However, new targets are also emerging, including electric vehicles and their battery supply chains, pharmaceuticals, and medical devices. New Withhold Release Orders and findings outside of China can also be expected to be issued. 
• The United States will continue to use novel measures to combat forced labor, including Section 301, free trade agreements, and bilateral deals and frameworks. Pending US state forced labor laws should also be on companies’ radars. 
• International enforcement coordination will pick up. Companies should anticipate increased information sharing among international customs authorities as allied nations implement or strengthen their own forced labor import restrictions — particularly under recent trade deals and frameworks. Multinational companies will need to assess forced labor programs to ensure they satisfy requirements in the new jurisdictions with forced labor compliance requirements.
• Technology will be key for both government enforcement targeting and importers’ supply chain due diligence efforts. Governments can be expected to increasingly leverage technology and data analysis to target priority sectors. At the same time, companies can use evolving technologies to assist with forced labor diligence.

“This report provides a thorough review of the forced labor law landscape at a pivotal moment. For businesses, the message is clear: A reactive approach to forced labor compliance is not viable,” said Angela M. Santos, ArentFox Schiff partner and leader of the firm’s Customs Practice and Forced Labor Task Force. “Companies must proactively map their supply chains to identify exposure to high-risk regions and entities, implement robust due diligence programs, and prepare documentation sufficient to rebut the presumption of forced labor when goods are detained or excluded.” 

In addition to Santos, the lead authors of this year’s report were senior associates Mario A. Torrico and Lucas A. Rock. To learn more about the firm’s Forced Labor Task Force and to explore the full guide, please click here.