Modern slavery reporting set for major overhaul

The UK government’s Immigration and Asylum Bill 2026 (the Bill) proposes significant changes to the transparency and reporting obligations under the Modern Slavery Act 2015 (MSA). If implemented, the reforms would transform the current reporting regime from a largely principles-based framework to a more prescriptive compliance obligation supported by substantial financial penalties.

The proposed reforms are likely to shift the focus from primarily a disclosure exercise towards demonstrable risk management, governance and supply chain due diligence.

Although the timing remains uncertain, businesses should begin assessing their approach now, as many of the proposed changes may require enhanced internal processes, controls and evidence gathering.

What’s changing?

The Bill introduces several key reforms:

1. Mandatory reporting requirements

Currently, organisations within scope of section 54 MSA have considerable discretion over the content of their annual statements. The Bill would replace this approach with mandatory reporting for companies/organisations and their subsidiaries across:

• organisational structure, operations and supply chains
• identification of and mitigation against modern slavery risks
• policies addressing slavery and human trafficking
• due diligence processes
• training (not just in relation to the organisation’s staff, but also across the supply chain)
• measures used to assess effectiveness.

The proposed model adopts a ‘comply or explain’ approach, requiring organisations to either disclose what measures they have taken or explain why they haven’t done so. Businesses will no longer be able to omit areas of reporting or rely on generic narrative statements. Robust evidence may be needed to support any explanation that a particular assessment or control hasn’t been undertaken.

2. New financial penalties

The Bill introduces, for the first time, a meaningful enforcement regime. Financial penalties could be imposed for non-compliance with reporting obligations, subject to a maximum of £1 million or 1% of annual turnover, whichever is higher.

Importantly, penalties aren’t limited to a complete failure to publish a statement. They could potentially apply where statements fail to contain required information, are submitted late, or don’t comply with procedural requirements.

The detailed enforcement framework will be set out in future regulations.

3. Hard publication deadline and enhanced certification

The Bill would introduce a power to make regulations to require modern slavery statements to be submitted to the Secretary of State electronically, most likely via the online Modern Slavery Statement Registry. Statements would need to be published within six months of the end of the relevant financial year and:

• be approved through existing governance processes
• include an accuracy declaration
• state the dates of approval and signature
• be signed by an appropriate senior individual.

As drafted, the Bill doesn’t create personal liability for signatories, but the requirement for an accuracy declaration is likely to increase scrutiny and necessitate internal assurance processes.

4. Extension to public authorities

The reporting duty would also extend to qualifying public authorities. This may have implications beyond public sector bodies so organisations supplying goods or services to government and public sector clients may face increased requests for supply chain information and due diligence evidence, as public authorities seek to meet their own reporting obligations.

Preparing for modern slavery reporting changes

Although we don’t yet have a timescale for implementation of reforms, businesses can take the following proactive steps now:

• undertake a gap analysis against the proposed mandatory reporting areas
• review supply chain risk assessment and due diligence processes
• assess the availability and quality of data used to support modern slavery reporting
• strengthen governance and approval procedures ahead of director-level certification requirements
• review supplier contracts, audit rights and monitoring arrangements
• monitor future consultations and regulatory developments.

Early preparation will help organisations reduce compliance risk and avoid having to make difficult public disclosures about gaps in their approach once the new framework is in force.

While the bill doesn’t go so far as mandating human rights due diligence in supply chains, this is something to keep an eye on in terms of government approach. Certainly, the bolstering of the modern slavery regime is consistent with a wider trend towards seeking to impose greater corporate accountability for risks arising in supply chains and other third-party relationships. From an employment law perspective this can be seen in the Employment Rights Act 2025 where, for example, from the end of October employer liability for third party harassment will be introduced.

How we can help

Our Employment and Commercial lawyers are experienced and expert in advising businesses across a wide range of sectors on ESG risks, supply chain governance, responsible business practices and modern slavery compliance. We can help organisations assess the impact of the proposed reforms, identify gaps in existing reporting processes and develop practical, proportionate approaches to managing modern slavery risk.

Get in touch to find out how we can help you with supply chain due diligence, supplier onboarding and contractual controls, modern slavery statements, governance frameworks, internal investigations, regulatory compliance and staff training. We can also help you navigate evolving UK and international supply chain regulations, enabling you to take a joined-up approach to modern slavery, forced labour and wider ESG obligations across your operations and value chains.

We’ll continue to monitor and report on progress of the Bill.