Significant reforms to modern slavery reporting requirements

The Immigration and Asylum Bill proposes significant reforms to modern slavery reporting requirements. The changes will introduce stricter reporting requirements and financial sanctions, increasing the burden on businesses to report on their supply chains in an effort to drive transparency. 

The proposal is to amend section 54 of the Modern Slavery Act 2015 (the Act), which requires certain large commercial organisations to publish a modern slavery statement setting out the steps they have taken in the previous financial year to prevent modern slavery and human trafficking in their business and supply chains. Since its introduction in 2015, compliance has been driven mainly by ESG considerations, stakeholder scrutiny and procurement requirements. Failing to publish a statement has typically carried reputational, rather than legal, consequences. 

Although the date for implementation is not yet clear, changes have been expected since the Queen’s speech in 2022. For many years, the UK’s modern slavery reporting regime has been criticised for falling behind international standards, lacking mandatory disclosures and having an ineffective enforcement process.  For more information on the background to these changes please read our previous legal updates. The tide is turning - navigating Modern Slavery and Forced Labour Regulations and Section 54 Modern Slavery Act – where do we go from here?.

In this update, we highlight the key changes, and steps organisations should be considering now.

Key changes

Mandatory statement content

The current legislation identifies information that a modern slavery statement may include, but organisations have not been required to do so. While the statutory guidance on Transparency in supply chains was significantly updated in 2025, organisations are not legally required to adhere to it.

The proposed reforms make reporting against existing prescribed topics mandatory, requiring organisations to address the following areas in their annual statement:

1. the organisation's structure, operations and supply chains; 
2. identification and mitigation of risk areas relating to modern slavery and human trafficking; 
3. policies on slavery and human trafficking; 
4. due diligence processes; 
5. staff and supply chain training; and 
6. an assessment of the effectiveness of the steps taken against performance indicators. 

If an organisation has not taken action in a particular area, it must explain why rather than simply omitting it. The option for an organisation to publish a modern slavery statement confirming that it has taken no steps will still be possible, but the circumstances in which such a statement will be appropriate are minimal. 

Senior approval and accuracy declarations

The current regime already requires statements to be approved and signed at a senior level. For companies, this means approval by the board of directors and signature by a director, with equivalent requirements applying to LLPs and partnerships.

The proposed reforms retain these approval requirements but also introduce a new accuracy declaration. The individual signing the statement must confirm that, to the best of their knowledge and belief, the statement is accurate. Parent undertakings will also be permitted to approve and sign statements on behalf of subsidiary companies. This places a heightened obligation on the director signing the statement, with compliance with directors’ duties being placed front and centre.

Extension to public authorities

Public authorities are currently outside the scope of the statutory reporting regime, although many comply on a voluntary basis.

The proposed new section 54ZA extends the reporting duty to public authorities above a prescribed budget threshold, to be set by regulations and likely to be in line with the £36 million annual global turnover applied to private sector organisations. Statements must be certified by the relevant public authority or, where appropriate, another public authority, and signed by the most senior official responsible for its day-to-day operations or the next most senior official able to act.

Publication and submission

Currently organisations must publish their statement on their website and provide a prominent link to it on their homepage. Statutory guidance recommends publication within six months of the relevant financial year end and encourages organisations to upload statements to the Government's modern slavery statement registry, but the guidance is not mandatory.

The proposed reforms would retain the existing website publication requirement, require the statement to be published as soon as possible after the relevant financial year end, and give the Secretary of State power to make regulations requiring electronic submission to the Government’s registry. 

Enforcement

The most fundamental change is the introduction of financial sanctions for non-compliance. At present, while the Home Office can require compliance via injunctive action no such step has been taken. 

The proposed amendments set out financial penalties for non-compliance without ‘reasonable excuse’, capped at the higher of 1% of total turnover (or total budget for public authorities) and £1 million. Only one financial penalty may be imposed in relation to each annual statement. Regulations will provide for warning notices, representations and appeal rights. 

Next steps

While we await a timetable for implementation, organisations should be taking steps now to prepare for change by:

• Reviewing reporting processes against all six mandatory topics. Organisations should assess whether their current statement meets the requirements and begin filling any gaps now.
• Establishing board-level governance. Organisations should put in place clear approval and sign-off processes to support the personal declaration of accuracy.
• Assessing supply chain exposure. Organisations should map international supply chains, and take particular note where suppliers may also be subject to the EU Forced Labour Regulation or other mandatory due diligence requirements.
• Monitoring the parliamentary timetable. Commencement will be set by regulations, so organisations should be ready to comply once the relevant provisions come into force.

For more information on modern slavery or staff training, please contact one of your usual CMS team contacts. We offer two modern slavery e-learning modules: one for all staff and one focused on manager training. Click on the link for more details. Modern slavery and human trafficking | CMS eLearning | CMS UK

Co-authored by Chloe Atkins, Trainee Solicitor CMS UK.