UK Government looks to extend corporate reporting obligations for modern slavery

The UK Government has proposed significant reforms to the modern slavery corporate reporting regime as part of the Immigration and Asylum Bill, which was introduced to Parliament on 30 June 2026 and received its second reading on 13 July 2026. The Bill is expected to undergo further Parliamentary scrutiny when Parliament returns in the autumn

If enacted, the reforms would represent the most significant changes to the transparency requirements under section 54 of the Modern Slavery Act 2015 since they were introduced. Key proposals include: 

• an extension of reporting obligations to certain public authorities (yet to be specified);
• a requirement that an entity’s modern slavery statement addresses its risk of exposure to slavery/human trafficking, its relevant policies, due diligence processes and training and an assessment of the entity’s “effectiveness” in ensuring that slavery and human trafficking is not taking place in its operations or supply chains;
• greater senior accountability, with annual statements requiring certification, approval, signature and an accuracy declaration from an appropriate senior person; and
• financial penalties of up to the greater of £1 million or 1% of annual turnover for non-compliance. 

Notably, the Bill does not currently introduce a mandatory human rights due diligence regime, despite previous recommendations from parliamentary committees and other stakeholders.

The reforms raise an important question: should modern slavery reporting be viewed simply as another annual compliance exercise, or as a tool for generating meaningful data, improving risk management and contributing to the reduction of forced labour in global supply chains?

Background – why is change being proposed?

The UK's transparency in supply chains regime was widely regarded as pioneering when introduced in 2015. However, criticism of the framework has steadily grown over the last decade. 

• The 2019 Independent Review of the Modern Slavery Act concluded that reporting quality was inconsistent, enforcement mechanisms were weak and compliance levels remained too low. It recommended mandatory reporting categories, stronger monitoring and greater accountability for organisations within scope.
• Critics have also argued that section 54 focuses on disclosure rather than action. Organisations are required to publish a statement, but are not required to undertake any specific due diligence measures and can currently comply even where no steps have been taken to address modern slavery risks.
• Those concerns were echoed in a 2021 report by researchers from the University of Oxford and BIICL, which criticised the UK's "light-touch" approach and questioned whether section 54 had achieved meaningful changes in corporate behaviour or materially reduced modern slavery risks in practice.
• At the same time, other jurisdictions have continued to develop their regimes. The EU has adopted both the Corporate Sustainability Due Diligence Directive and Forced Labour Regulation, whilst Australia has recently proposed reforms that would introduce a new offence for large organisations that fail to prevent modern slavery in their supply chains unless they can demonstrate that reasonable preventative steps were taken. Against that backdrop, many commentators have argued that the UK framework has fallen behind international developments. 

Will the proposals address the existing criticisms?

To some extent, yes.

• Rightly or wrongly, the current regime is viewed as lacking teeth; the sole existing sanction for a corporate’s failure to publish a modern slavery statement is for the Secretary of State to apply for an injunction compelling it to do so, and this power has not been exercised to date.  The proposals add real bite in the form of a serious financial penalty.
• The new accuracy declaration and senior approval requirements also appear designed to move responsibility for modern slavery reporting further into the boardroom, encouraging greater ownership of the underlying systems and data used to support disclosures. 

However, the reforms stop short of introducing a positive duty to identify, prevent or remediate modern slavery risks. The focus remains on better transparency, rather than mandatory human rights due diligence. As a result, the UK would continue to take a different approach from some of the more interventionist regimes emerging internationally. 

What does this mean for businesses and senior leaders?

Whilst the Bill remains at an early stage, it signals a shift towards a more prescriptive transparency regime with fines for those that fail to comply. Businesses already reporting under the existing framework will need to keep an eye on the evolution of this legislation and consider whether current governance, due diligence and supply chain oversight processes would withstand increased scrutiny. 

For in-house legal teams, the practical challenge may be less about producing additional reports and more about ensuring that governance frameworks, supply chain risk assessments and due diligence processes can support more detailed and prescriptive disclosures. 

For directors and senior officers, the proposed approval and accuracy requirements are likely to require increased board-level engagement with modern slavery compliance. Combined with potentially significant financial penalties, this could elevate modern slavery reporting from an annual disclosure exercise to a more prominent governance and risk management issue. 

Businesses already reporting under the existing framework will need to keep an eye on the evolution of this legislation and consider whether current governance, due diligence and supply chain oversight processes would withstand increased scrutiny.