The UK Modern Slavery Act is the primary supply chain transparency law for businesses operating in the United Kingdom. If your company has a UK presence and £36M+ turnover, you are required by law to publish an annual modern slavery statement. This guide covers what the Act requires, what's changing in 2024–2025, and a practical 5-step compliance checklist to protect your business and supply chain.
The UK Modern Slavery Act 2015 is the primary piece of UK legislation targeting slavery, servitude, forced labour, and human trafficking. It criminalises these acts and — critically for businesses — requires large commercial organisations to be transparent about the steps they are taking to eradicate modern slavery from their supply chains.
The transparency requirement is Section 54 of the Act, which requires in-scope organisations to publish an annual Modern Slavery Statement. This statement must set out what the organisation has done during the financial year to identify and address modern slavery risks, including in its own operations and those of its suppliers.
Unlike purely criminal law, Section 54 operates on a disclosure model — it requires transparency, not a specific outcome. However, the Modern Slavery Bill introduced in September 2024 proposes to shift this toward mandatory enforcement, including digital reporting to a central government registry and import bans on forced-labour goods.
The Home Office's Transparency in Supply Chains etc. Regulations 2015 (the secondary legislation under Section 54) sets out the minimum standards for modern slavery statements and the due diligence expected from in-scope businesses.
Any UK or non-UK incorporated company or partnership that carries on a business in the UK and has a total annual turnover of £36 million or more. This threshold captures approximately 12,000–17,000 organisations. Turnover is calculated before tax and includes the entire organisation, not just UK revenue.
A subsidiary must use the group's total worldwide turnover to determine if it meets the threshold. If the parent group's combined turnover exceeds £36M, every subsidiary within that group is required to produce a modern slavery statement — even if the subsidiary's own revenue is below the threshold.
Any foreign-incorporated company that 'carries on a business, or part of a business, in the UK' above the £36M threshold is in scope. This covers US, EU, Asian, and other multinationals with a UK office, UK subsidiaries, or significant UK customer contracts. Non-UK companies with no formal UK presence but significant UK revenue may still be captured under 'carrying on business' definitions.
While the Act primarily targets the private sector, the government has increasingly expected large public sector bodies and government contractors to comply with modern slavery reporting requirements. Government procurement requirements (Public Contracts Regulations) increasingly make modern slavery statements a precondition for public contracts.
These sectors face the highest scrutiny under the UK MSA due to the prevalence of agency labour, seasonal workers, subcontracting chains, and migrant worker exploitation. The 2024 Modern Slavery Bill specifically targets high-risk sectors for enhanced reporting requirements.
Brands importing from countries with high forced labour risk — Southeast Asia, South Asia, Eastern Europe — face the most intense scrutiny from UK enforcement bodies, NGOs, and the media. The Rana Plaza disaster legacy means UK fashion and retail brands face reputational pressure beyond legal compliance.
Every in-scope organisation must publish a modern slavery statement annually. The statement must cover six mandatory areas as specified in the 2015 Regulations:
The statement must be approved by the board of directors (or equivalent governing body), signed by a director or senior manager, and published on your website — ideally with a link from every page footer.
The UK MSA expects organisations to conduct meaningful due diligence across their supply chains:
Not sufficient: A one-page questionnaire sent to suppliers once a year, or a generic policy statement with no operational follow-up. The Home Office expects documented, ongoing engagement with supply chain risk.
A risk assessment is both a legal requirement and your primary defence against enforcement action:
The risk assessment must be documented, reviewed annually, and updated when sourcing decisions change. It forms the basis for your statement's description of due diligence activity.
Modern slavery policies only work if staff can identify and act on risk indicators:
The UK MSA requires organisations to measure and disclose progress on their anti-slavery commitments. Effective KPIs include:
Honest, candid reporting — including where you've fallen short — is more credible than overstating compliance. The government's independent reviewer of the Act has criticised 'boilerplate' statements that provide no real insight.
The Act requires that the modern slavery statement is approved by the board and signed by a director or equivalent senior figure. This is not a box-ticking exercise — it signals that modern slavery risk is a governance-level concern, not just a compliance function:
The UK government's Modern Slavery Bill, introduced in Parliament on 11 September 2024, represents the most significant reform of the Act since 2015. Key proposals and enforcement updates:
The 2024 Bill requires in-scope organisations to submit their modern slavery statements to a dedicated government-run transparency register, replacing the current system where statements are only published on company websites. This creates a public, searchable database of UK business compliance. A mandatory registry makes non-compliance more visible and creates a systematic enforcement mechanism. Expected: 2025–2026.
The Bill introduces new powers to ban the import of goods produced with forced labour into the UK — analogous to the US UFLPA but at UK border level. UK Border Force will have powers to seize and destroy shipments. This adds a trade enforcement dimension to the existing transparency framework. Companies with global supply chains will need to ensure their sourcing practices can withstand UK-origin verification. Expected: 2026.
The updated Act strengthens the role of the Independent Anti-Slavery Commissioner, granting new powers to investigate organisations, require information, and issue compliance notices. Commissioner reports have repeatedly criticised boilerplate statements — the new enforcement powers mean organisations can no longer rely on generic disclosures.
Proposed amendments include requirements for multi-year trend reporting (showing progress against prior year commitments) and — for high-risk sectors — independent third-party verification of statement claims. This will raise the bar for what constitutes a credible statement and make boilerplate language indefensible.
The Home Office has increased scrutiny of published statements, with the Business and Trade Committee publishing critical reports on the quality of UK MSA disclosures. The Secretary of State has powers to publish the names of organisations that fail to comply. The 2024 Bill strengthens this naming power and creates a streamlined process for public designation of non-compliant organisations.
Action: Confirm your organisation meets the £36M annual turnover threshold (use group-wide turnover for subsidiaries). Appoint a named board-level or senior director owner of modern slavery compliance. Establish a cross-functional working group (procurement, legal, HR, compliance, sustainability).
Check: Review the Home Office guidance (Transparency in Supply Chains etc. Regulations 2015) and the Modern Slavery Registry for examples of good and poor statements. The Independent Anti-Slavery Commissioner's office also provides sector-specific guidance.
Action: Document your supply chain structure — all direct (Tier 1) suppliers and, where possible, indirect (Tier 2+) suppliers. Conduct a risk assessment prioritising by geography, sector, labour intensity, and known exploitation indicators. Identify your highest-risk categories: agency labour, seasonal workers, agricultural workers, cleaning, construction, logistics.
Output: A documented supply chain map and risk register. This is the foundation of your statement's 'risk assessment' section and your defence if challenged.
Action: Publish or update a modern slavery policy (approved by the board). Embed anti-slavery clauses into supplier contracts — require suppliers to represent that neither they nor their sub-suppliers use forced labour, and grant audit rights. Launch a training programme for procurement, HR, and operations staff. Create an accessible reporting channel for workers in your supply chain to raise concerns without retaliation.
Resources: The Home Office has published a transparency template and procurement guidance. The Chartered Institute of Procurement and Supply (CIPS) has sector-specific training resources.
Action: Commission third-party audits of your highest-risk suppliers (those in high-risk geographies or sectors). Require all Tier 1 suppliers to self-certify compliance with your anti-slavery standards. Establish a grievance mechanism that workers in your supply chain can actually access — translated into relevant languages, non-retaliation guaranteed, with documented follow-up.
Prioritisation: Start with your top 20–50 highest-risk direct suppliers. Expand as capacity grows. Document every audit finding and remediation action — this demonstrates 'due diligence' and mitigates liability if issues arise.
Action: Write your statement covering all six mandatory areas of the 2015 Regulations. Be specific — use real data, real KPIs, real challenges and real plans. Get the statement approved at board level, signed by a director, and published on your website with a visible link (not buried in a PDF). Update annually with year-on-year progress against your stated commitments.
Quality bar: The Independent Anti-Slavery Commissioner and parliamentary committees have explicitly called out boilerplate statements as inadequate. A statement that says nothing specific is a compliance risk, not a compliance defence.
Non-compliance with the UK MSA carries significant legal, financial, and reputational risk — and the 2024 Bill substantially increases enforcement exposure.
Under the 2023–2024 amendments, organisations that fail to publish a statement face unlimited fines — no statutory maximum. For large companies, this means fines can reach millions of pounds. The Business and Trade Committee has recommended escalating penalties for repeat non-compliers.
The Secretary of State can name organisations that fail to comply with Section 54 on a public transparency register. Being listed as non-compliant is highly damaging to brand reputation, B2B relationships, and government contract eligibility. The 2024 Bill accelerates and automates this process.
The courts can issue injunctions requiring organisations to take specific steps to comply with the Act. Non-compliance with a court injunction constitutes contempt of court — carrying additional sanctions and criminal penalties.
Once the forced labour import ban provisions take effect, UK Border Force can seize and destroy shipments of goods produced with forced labour. This creates operational supply chain disruption risk that no UK business can afford to ignore.
Section 1 of the Act criminalises slavery, servitude, and forced labour with a maximum sentence of life imprisonment for the most serious offences. These offences apply to individuals — directors, managers, and HR personnel who knowingly facilitate exploitation face personal criminal liability.
Beyond legal penalties, modern slavery revelations destroy brand value, trigger investor concern, cause customer boycotts, and end procurement relationships. The reputational half-life of a modern slavery scandal extends for years — the legacy of well-known cases (Sports Direct, Boohoo) illustrates how damaging supply chain exploitation can be.
Know exactly where your supply chain stands on UK Modern Slavery Act requirements, US UFLPA obligations, and EU CSDDD requirements. Get an instant risk report with prioritised recommendations.
Assess Your Compliance Risk →The UK MSA is a transparency law — it requires large organisations to publish a statement describing their anti-slavery efforts but doesn't ban specific imports. The US UFLPA (Uyghur Forced Labor Prevention Act) is an import ban — it presumes goods from Xinjiang are made with forced labour and blocks them at the US border unless importers prove otherwise. Both require supply chain due diligence, but UFLPA is enforced at the US border; the UK MSA is enforced through disclosure requirements and (under the 2024 Bill) import bans. Many UK-based multinationals need to comply with both.
The Act currently has no direct enforcement mechanism for 'inadequate' statements — only for failing to publish one. However, the Independent Anti-Slavery Commissioner can name and criticise organisations publishing poor statements, parliamentary committees can summon companies to explain their disclosures, and the press scrutinises high-profile cases. The 2024 Bill proposes financial penalties for materially inadequate statements, not just absent ones. Start treating statement quality as a legal risk, not just a reputational one.
Yes — the MSA requires organisations to address modern slavery risks in their supply chains, which includes overseas suppliers. The due diligence requirement covers your entire supply chain, not just UK-based operations. The Home Office guidance explicitly expects organisations to understand and address risks upstream, regardless of geography. The 2024 Bill's import ban provisions make this even more critical — UK Border Force will scrutinise goods produced with forced labour anywhere in the world.
Supplier non-cooperation is a compliance red flag. First, embed audit rights and anti-slavery compliance requirements in your contract template — make disclosure a contractual obligation. If a supplier refuses, escalate formally (document all communications). Consider the severity of the risk: for high-risk suppliers, non-cooperation may justify disengagement. For lower-risk suppliers, engage through capability building first. Document your efforts — the due diligence defence requires you to demonstrate good-faith efforts, even if a supplier ultimately refuses to cooperate.
The UK MSA (2015) requires a public statement but has limited enforcement for inadequate disclosures. The EU CSDDD (Corporate Sustainability Due Diligence Directive, applying from 2027–2029) requires in-scope companies to actually implement a due diligence programme — with defined processes, prevention obligations, and civil liability for failure. CSDDD applies to large companies (1,000+ employees, €450M+ turnover); UK MSA applies to companies with £36M+ turnover (broader scope). Companies that need to comply with both should build a single programme that satisfies both frameworks — the core due diligence requirements largely overlap.
Yes. A well-written modern slavery statement creates evidence of due diligence that supports compliance with other frameworks — the California Transparency in Supply Chains Act, ISO 37001 (anti-bribery), ISO 20400 (sustainable procurement), and ESG reporting standards. The same supply chain mapping, risk assessment, and audit programme satisfies multiple requirements. For SMEs that supply large companies, your MSA statement also serves as evidence of compliance when your customers conduct their own due diligence on you.
The Act requires organisations to describe the steps they take to train staff on modern slavery — but doesn't specify a particular format or frequency. Best practice includes: mandatory training for procurement and HR teams on identifying forced labour indicators; awareness training for all staff on the organisation's modern slavery policy and how to report concerns; supplier-facing training on expectations and compliance requirements. Training records should be maintained and included in your statement's KPIs section.
Annually. The statement must reflect the steps taken during the financial year and be published within six months of the financial year end (for most companies, by 31 March each year for a 31 March year-end). The statement must also describe your plans for the coming year — so each annual cycle builds on the previous one. As the 2024 Bill progresses, multi-year trend reporting is expected to become mandatory, making consistent annual publication even more important.
Evaluate your UK MSA, UFLPA, CSDDD, and CA Transparency Act compliance in 5 minutes. Get an instant risk report with prioritised recommendations.
The Uyghur Forced Labor Prevention Act targets Xinjiang-origin imports at the US border. Many UK-based importers also need to comply with UFLPA. Learn the US framework and its relationship to UK MSA obligations.
The EU Corporate Sustainability Due Diligence Directive creates binding due diligence obligations for large companies. If you have EU revenue, the CSDDD may apply alongside your UK MSA obligations. Learn both frameworks here.
Hospitality, construction, agriculture, and fashion face the highest forced labour risk in UK supply chains. See industry-specific breakdowns, enforcement history, and sector-specific compliance guidance.
The EU's forced labour product ban complements the UK MSA with a hard market withdrawal mechanism. Companies selling into both UK and EU markets need to comply with both frameworks. EU Commission guidelines due June 2026.
UK automotive manufacturers and importers with supply chains in China and Southeast Asia face overlapping UK MSA, UFLPA, and EU 2024/3015 obligations. See how automotive compliance requirements intersect across all three frameworks.