Supply Chain Due Diligence

Modern Slavery Reporting Readiness

The Modern Slavery Act 2015 (s.54) already requires commercial organisations with £36m+ annual turnover to publish a slavery and human trafficking statement. But the regime is about to get teeth.

The UK Government’s Immigration and Asylum Bill, introduced on 30 June 2026, proposes financial penalties of up to the higher of £1 million or 1% of turnover for non-compliance. Committee stage is expected to conclude by 3 November 2026. This is a Bill, not yet law — but the direction of travel is clear. Organisations that prepare now will avoid a reactive scramble when enforcement begins.

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Current Requirements Under the Modern Slavery Act

Section 54 of the Modern Slavery Act 2015 requires commercial organisations with annual turnover of £36 million or more to publish a slavery and human trafficking statement for each financial year. The statement must describe the steps the organisation has taken to ensure slavery and human trafficking is not taking place in its supply chains or its own business — or state that it has taken no such steps.

The Government launched a voluntary Modern Slavery Statement Registry in March 2021. However, there are currently no direct financial penalties for non-compliance with s.54 — the only enforcement mechanism is an injunction by the Secretary of State.

What the Bill Proposes to Change

Note: The provisions below are from the Immigration and Asylum Bill introduced 30 June 2026. They are proposed amendments, not yet enacted. RSustain will update this page as the Bill progresses through Parliament.

Financial Penalties

Proposed fines of up to the higher of £1 million or 1% of turnover for failure to publish a compliant statement. Only one penalty per organisation per financial year.

Mandatory Content & Expanded Scope

Statements would need to cover prescribed topics on a “comply or explain” basis, including due diligence processes, risk assessment, training, and remediation. The scope would also extend to public authorities. Generic “no steps taken” statements are unlikely to satisfy the new regime.

Enforcement Mechanisms

Proposed tools include warning notices, cost recovery for enforcement, interest on late payments, and public disclosure of non-compliant organisations.

Expected Timeline

Committee stage expected by 3 November 2026. If enacted, enforcement is expected to apply to statements for financial years commencing in 2027, with secondary legislation setting transitional provisions.

How RSustain Supports Readiness

Statement Quality Review

Benchmarking your current statement against the proposed mandatory content requirements and best-practice examples. Identification of gaps that would attract regulatory scrutiny.

Supply Chain Risk Mapping

Systematic assessment of modern slavery risks across your supply chain tiers. Country-risk analysis, sector-risk profiling, and identification of high-risk suppliers for deeper due diligence.

Due Diligence Framework

Design and implementation of a proportionate due diligence framework aligned with the UN Guiding Principles on Business and Human Rights. Supplier questionnaires, audit protocols, and escalation procedures.

Training & Governance

Board-level briefings, procurement team training, and establishment of internal governance structures for ongoing modern slavery risk management.

EU CSDDD & Cross-Border Considerations

The EU Corporate Sustainability Due Diligence Directive (CSDDD) imposes human rights and environmental due diligence obligations on large EU companies and non-EU companies with significant EU activity. The Omnibus I Directive (entered into force 18 March 2026) narrowed the scope from approximately 13,000 to roughly 6,000 companies, reduced liability provisions, and delayed application timelines. UK companies with EU operations or EU customers may face due diligence requests under both regimes. RSustain helps design integrated frameworks that satisfy both the UK Modern Slavery Act and EU CSDDD requirements.

Related Services & Resources

Frequently Asked Questions

Who needs to publish a modern slavery statement?+

Under the Modern Slavery Act 2015 s.54, any commercial organisation with annual turnover of £36 million or more that carries on business (or part of a business) in the UK must publish a slavery and human trafficking statement for each financial year.

Is the Modern Slavery Bill law yet?+

No. The proposed amendments to the Modern Slavery Act are contained in the Immigration and Asylum Bill, introduced on 30 June 2026. Committee stage is expected to conclude by 3 November 2026. The Bill must pass through both Houses of Parliament before receiving Royal Assent. RSustain recommends preparing now so your reporting framework is ready if and when enforcement begins.

What penalties are proposed?+

The Bill proposes financial penalties of up to the higher of £1 million or 1% of turnover. Enforcement tools would include warning notices, cost recovery, interest on late payments, and public disclosure of non-compliant organisations.

How does this relate to the EU CSDDD?+

The EU Corporate Sustainability Due Diligence Directive (CSDDD) imposes broader human rights and environmental due diligence obligations on large companies. While the UK Modern Slavery Act focuses specifically on slavery and trafficking in supply chains, companies with EU exposure may need to satisfy both regimes. The Omnibus I Directive (March 2026) narrowed CSDDD scope to approximately 6,000 companies.

What is the Modern Slavery Statement Registry?+

The UK Government launched a voluntary Modern Slavery Statement Registry in March 2021. Organisations can upload their statements for public access. The proposed reforms may make registry submissions mandatory.

Prepare Now, Not When Enforcement Begins

Book a free scoping call to assess your modern slavery reporting readiness and build a framework that will withstand the coming enforcement regime.

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