The UK Modern Slavery Act 2015 has been widely described as a “toothless tiger” — requiring statements but imposing no financial penalties for non-compliance. That is about to change. The Immigration and Asylum Bill, introduced on 30 June 2026, proposes fines of up to the higher of £1 million or 1% of turnover. Here is what you need to know.
Current Requirements: Modern Slavery Act 2015, Section 54
Section 54 requires commercial organisations with annual turnover of £36 million or more that carry on business in the UK to publish an annual slavery and human trafficking statement. The statement must describe steps taken to ensure modern slavery is not occurring in the organisation’s business or supply chains — or state that no such steps have been taken.
The Act lists six suggested topic areas (structure, policies, due diligence, risk areas, KPIs, training) but these are currently not mandatory. The only enforcement mechanism is an injunction by the Secretary of State, which has never been exercised.
The Government launched a voluntary Modern Slavery Statement Registry in March 2021, but submissions are not yet required.
What the Immigration and Asylum Bill Proposes
Note: The provisions below are from a Bill introduced on 30 June 2026. They are proposed amendments, not yet enacted. Committee stage is expected to conclude by 3 November 2026.
- Financial penalties: Up to the higher of £1 million or 1% of turnover for failure to publish a compliant statement
- Mandatory prescribed content: Statements would need to cover prescribed topics on a “comply or explain” basis
- Extended scope: Obligations would extend to public authorities, not just commercial organisations
- Enforcement tools: Warning notices, cost recovery, interest on late payments, and public disclosure of non-compliant organisations
- Registry: Submission to the Modern Slavery Statement Registry would become mandatory
- Accuracy statement: Signatories would need to include an accuracy statement; parent undertakings could sign on behalf of subsidiaries
If enacted, enforcement is expected to apply to statements for financial years commencing in 2027.
EU CSDDD: The Broader Due Diligence Landscape
The EU Corporate Sustainability Due Diligence Directive (CSDDD) imposes broader human rights and environmental due diligence obligations. The Omnibus I Directive (entered into force 18 March 2026) narrowed the scope from approximately 13,000 to roughly 6,000 companies, with application from 26 July 2029 for in-scope companies.
UK-headquartered companies generating EUR 1.5 billion or more in net EU turnover will be subject to CSDDD obligations regardless of UK legislation. This creates an extraterritorial overlap for the largest UK businesses.
What Should You Do Now?
- Review your current statement against the proposed mandatory content requirements — generic “no steps taken” statements will not survive the new regime
- Map supply chain risks by country and sector, focusing on high-risk geographies and labour-intensive supply chains
- Establish due diligence processes aligned with the UN Guiding Principles on Business and Human Rights
- Train procurement teams on modern slavery indicators and escalation procedures
- Consider a Modern Slavery Readiness assessment to identify gaps before enforcement begins
RSustain Advisory
RSustain’s Modern Slavery Readiness service covers statement quality review, supply chain risk mapping, due diligence framework design, and board-level training. Book a free scoping call.
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