The (current) Home Secretary Shabana Mahmood introduced the Immigration and Asylum Bill to Parliament on 30 June 2026. Despite the immigration focus, this legislation introduces wide-ranging reforms to the modern slavery compliance regime which has been in place since the Modern Slavery Act 2015.
The legislation has two key elements regarding modern slavery. The first is on the victim level. It would tighten elements of the modern slavery and victim identification support system. There’s a strong focus on offering additional protections to child victims of slavery, separated from the adult route. Some changes to the assessment procedure to decide if someone’s report of slavery is credible have been included. Ostensibly this is to cut down on false claims, and allows decision makers to consider factors like delayed or inconsistent disclosures, for instance a failed asylum seeker suddenly claiming modern slavery protections after their case has been rejected.
The second and more important element for companies is the expanded corporate compliance aspects through reforms to the Modern Slavery Act 2015. Modern slavery statements would become more formal, with mandatory content, stronger approval and signature requirements, government submission, fixed reporting deadlines and the possibility of significant financial penalties of up to £1m for non-compliance. In practice, the Bill would move the UK modern slavery regime closer to a regulated compliance framework, rather than a largely reputational transparency obligation.
What the current UK modern slavery law requires
The current UK modern slavery reporting regime is based on section 54 of the Modern Slavery Act 2015. It applies to commercial organisations that carry on business, or part of a business, in the UK, supply goods or services, and have annual turnover of at least £36 million. The organisation can be incorporated or formed in the UK or overseas, provided it has a sufficient UK business presence.
At present, the duty is essentially a transparency obligation. A covered organisation must publish an annual slavery and human trafficking statement explaining the steps it has taken during the financial year to ensure that slavery and human trafficking are not taking place in its business or supply chains. If it has taken no steps, it can say so. The law does not require the organisation to guarantee that its supply chain is slavery-free, just to publish a statement of steps, for instance, a risk assessment or training.
The current legal requirements on the statement are relatively limited. A statement must be approved by the board, or equivalent management body, and signed by a director, designated member or equivalent senior person depending on the organisation’s structure. It must also be published on the organisation’s website, with a prominent link on the homepage. Statements should be published within six months of the financial year end.
The MSA 2015 Act outlines six areas that a statement may cover:
- the organisation’s structure and supply chains
- policies
- due diligence
- risk assessment and management
- effectiveness and KPIs
- training
These areas are important in practice, and they are reflected in Home Office guidance, although they are not currently mandatory content requirements in the same way the new Bill proposes.
Uploading a statement to the current government modern slavery statement registry is also voluntary. Organisations are encouraged to add their statements to the registry, and the registry is intended to improve transparency and comparability, although publication on the registry is not currently the same as a mandatory submission obligation. There are also no specific penalties for failing to publish a statement.
What the new Bill proposes to change
The Immigration and Asylum Bill would substantially tighten the modern slavery reporting regime. The Bill specifically amends section 54 of the Modern Slavery Act 2015 by extending reporting to public authorities, mandating the topic areas that must be covered in a statement, mandating use of the Modern Slavery Statement Registry, and introducing enforcement penalties for non-compliance.
For businesses, the central change is that modern slavery reporting would move from a flexible transparency model to a more prescriptive compliance model. The Bill would create mandatory content requirements for slavery and human trafficking statements through a new Schedule 4ZA. That means organisations would need to address specific statutory areas, rather than choosing how much detail to provide under the current guidance-style headings.
The Bill would also strengthen governance around statements. Statements would need to be certified by the organisation to which they relate, or by a parent undertaking in the case of a subsidiary. They would need to be approved and signed by the appropriate senior person or body. The statement would also need to include a declaration that the information in it is accurate to the best of the signatory’s knowledge and belief.
Publication would become more formal. Organisations would still need to publish statements on their websites where they have one, with a prominent link. The Bill would also require statements, or links to statements, to be submitted electronically to the Secretary of State in the prescribed form. Statements would need to be published and submitted as soon as reasonably practicable after the financial year end, and no later than six months after the end of that financial year.
The final major change is enforcement. At present, the section 54 regime has been criticised because non-compliance has largely created reputational, customer and procurement risk. The Bill would introduce financial penalties for failures to comply with the statement duties. The maximum penalty would be the higher of £1 million or 1% of the relevant amount, which means turnover for commercial organisations and budget for public authorities.
What companies will be covered by the new modern slavery rules
For commercial organisations, the Bill appears to build on the existing section 54 framework. That means the starting point remains commercial organisations supplying goods or services, carrying on business or part of a business in the UK, and meeting the £36 million turnover threshold. Businesses should therefore assume that the existing population of in-scope companies will remain in scope, with a much more demanding set of obligations attached.
This matters for overseas companies as well as UK companies. Under the current regime, an overseas organisation can be required to publish a statement if it has a demonstrable business presence in the UK and meets the other criteria. The same compliance question is likely to become more significant under the new regime because the consequences of non-compliance would be more serious.
Corporate groups will need particular care. The current regime already allows group statements, and the Bill would allow statements to be certified by a parent undertaking on behalf of a subsidiary undertaking. That is helpful for large groups, although it means the parent will need assurance that the statement properly covers the risks, controls and activities of all entities included in it. A group statement that gives a high-level description of the parent company while ignoring higher-risk subsidiaries is unlikely to be a safe approach.
Public bodies
The Bill would extend modern slavery reporting duties to public authorities that meet a budget threshold to be set in regulations. This is a major expansion of the regime because modern slavery reporting would no longer be confined to commercial organisations. Public authorities would need to report annually on the steps they have taken to address modern slavery in their operations and supply chains.
This has a direct consequence for private-sector suppliers. Public bodies that are required to publish their own statements are likely to ask more detailed questions of suppliers, especially in procurement exercises, framework agreements and contract management processes. Even suppliers below the £36 million threshold may face stronger modern slavery information requests if they sell to public authorities or sit in the supply chain of larger companies.
What companies would need to do differently
Companies would need to treat the modern slavery statement as the output of a year-round compliance process, rather than a document updated shortly before publication. The Bill would make it harder to rely on generic wording, recycled statements or broad commitments unsupported by evidence.
Ownership
Modern slavery reporting would need clearer internal accountability across compliance, legal, procurement, HR, sustainability, operations and the board. Procurement may hold supplier data, HR may hold workforce and recruitment information, compliance may manage policies and training, and the board or senior signatory will need assurance before approval. The statement can no longer sit with one team as a drafting exercise.
Evidence
If the statement says the business carried out a risk assessment, implemented due diligence, trained staff, reviewed suppliers or measured effectiveness, the business should be able to show records behind those claims. That evidence might include risk assessment methodology, supplier questionnaires, due diligence outputs, contract clauses, audit findings, remediation plans, training completion data and board approval papers.
Timing
Since the Bill would set a six-month deadline for publication and submission, companies should build modern slavery reporting into the annual compliance calendar. Data collection should start before the financial year end. Drafting, review, board approval, signature, website publication and government submission all need owners and dates.
Board assurance
Because the Bill requires a declaration of accuracy from the person signing the statement, directors and equivalent senior signatories are likely to expect a more formal assurance pack. That should explain what the organisation has done, what risks were identified, what evidence supports the statement, what gaps remain, and what improvements are planned.
How modern slavery risk can be assessed
Modern slavery risk assessment should begin with the structure of the business. A company needs to understand where it operates, what it buys, who it employs, what labour models it uses, and which parts of its supply chain are most exposed to exploitation. The Bill would require statements to describe the organisation’s structure, operations and supply chains, and to identify where there is a risk of slavery or human trafficking in those operations and supply chains.
Risk should be assessed across several dimensions. Geography is an important factor because some jurisdictions have weaker labour enforcement, higher corruption risk, greater use of migrant labour or known forced labour concerns. Sectors are also relevant because areas such as agriculture, construction, cleaning, manufacturing, logistics, hospitality, care, security and garment production can present higher risks. Labour model often increases where there is outsourcing, subcontracting, seasonal labour, agency labour, informal recruitment, accommodation tied to employment, or labour providers charging recruitment fees.
Supplier tiering is also important. Many companies have reasonable visibility over direct suppliers and much weaker visibility over lower-tier suppliers. A credible modern slavery risk assessment should recognise that limitation. It should not pretend that the business has full visibility if it does not. The better approach is to explain what the business knows, where the visibility gaps are, and what steps are being taken to improve oversight.
The Bill also creates pressure to explain how the company reached its risk conclusions. If a company states that no part of its operations or supply chains is at risk, the statement would need to explain what steps were taken to assess that risk. If the company has not carried out a risk assessment, it would need to say so and explain why. That makes unsupported “low risk” statements much more difficult to defend.
In practice, companies should use a structured risk assessment process. That could combine supplier location, sector, spend, product or service type, workforce profile, use of subcontracting, past incidents, audit results, grievance data, whistleblowing reports, media screening and external risk indicators. The assessment does not need to be perfect. It does need to be rational, documented and capable of explaining why some areas are treated as higher risk than others.
How should modern slavery statements be changed
Modern slavery statements should become more specific, more structured and more evidence-based. Under the Bill, a statement would need to cover mandatory content areas, including the organisation’s structure, operations and supply chains, risk areas, steps taken to assess and reduce risk, policies, due diligence processes, training, and effectiveness.
The structure and supply chains section should do more than describe the business in corporate language. It should explain the parts of the organisation that are relevant to modern slavery risk. For example, a professional services business may have lower risk in its direct workforce, while still having risk in facilities management, cleaning, catering, IT hardware, events, travel or outsourced support. A manufacturing, retail or construction business may need much deeper discussion of suppliers, subcontractors, raw materials, sites and labour providers.
The risk section should be honest and practical. Companies should identify where risk may exist, rather than implying that the discovery of risk is itself a failure. Modern slavery statements are expected to show that the business understands and manages risk. A statement that identifies credible higher-risk areas and explains how the business is responding may be stronger than a polished statement claiming minimal risk without evidence.
The due diligence section should explain actual processes. It should describe supplier onboarding, risk screening, enhanced checks, contractual controls, supplier audits, worker engagement, grievance routes, escalation processes and remediation where relevant. Saying that suppliers are expected to comply with the law will not be enough for a more regulated regime.
The training section should distinguish between general awareness and role-specific training. All staff may need basic awareness of modern slavery and reporting channels. However more specialised teams like procurement, facilities or logistics and may need more detailed training because they are more likely to encounter risk indicators. Where supply-chain training information is reasonably available, the statement should also explain what training has been made available to supplier staff.
The effectiveness section should be improved significantly. Companies should explain how they know whether their controls are working. That means using KPIs or performance indicators where appropriate. Possible indicators include the percentage of high-risk suppliers assessed, number of enhanced due diligence reviews completed, number of audits, number of corrective action plans opened and closed, training completion rates, number of concerns raised, remediation outcomes and contract clause coverage.
The statement should be written with approval and enforcement in mind. Claims should be precise. Evidence should be retained. Dates of approval and signature should be clear. The signatory declaration should not be treated as a formality. If the board or director is declaring accuracy to the best of their knowledge and belief, the business needs a process that gives them a reasonable basis for doing so.
What are the penalties for non-compliance
The Bill would allow financial penalties for organisations that fail to comply with duties imposed by or under the modern slavery statement provisions. The proposed maximum penalty is the higher of £1 million or 1% of the relevant amount. For commercial organisations, the relevant amount is turnover. For public authorities, it is total budget.
Enforcement may include warning notices, recovery of enforcement costs, interest for late payment and publication of information about organisations that receive penalties. Only one financial penalty could be imposed on an organisation in relation to each slavery and human trafficking statement for a financial year. That still leaves significant exposure, especially for larger organisations where 1% of turnover could exceed £1 million.
The immediate penalty risk is likely to be failure to produce, approve, publish or submit a compliant statement. There may also be risk where the statement does not meet the mandatory content requirements, or where the organisation cannot substantiate claims made in the statement. The Bill does not appear to create a general offence of having modern slavery somewhere in the supply chain. The direct compliance risk is the failure to meet the reporting, governance, publication and submission obligations.
What to do now
The Bill is still making its way through Parliament, so businesses do not need to rewrite their modern slavery compliance programmes overnight. However, because this is a Government Bill, it should be treated as the likely outcome. The only caveat being the change of prime minister in July. This could create a different set of priorities, or even an early election, so there is no guarantee this legislation will make it to the statute book.
Nevertheless, compliance teams should monitor the Bill’s passage closely, including any amendments to the reporting provisions, commencement dates, penalty framework, public authority threshold and government submission process.
- Track the Bill’s passage through Parliament and monitor any changes to the modern slavery provisions.
- Check whether the organisation is already in scope under section 54 of the Modern Slavery Act 2015.
- Review the current modern slavery statement against the Bill’s proposed mandatory content areas.
- Confirm the statement is properly approved, signed, published and linked from the website homepage.
- Build an evidence file to support claims on policies, risk assessment, due diligence, training and effectiveness.
- Reassess modern slavery risk across suppliers, sectors, geographies, labour models and subcontracting arrangements.
- Strengthen supplier due diligence, especially for higher-risk suppliers and outsourced labour providers.
- Review staff training, with enhanced training for procurement, HR, recruitment, facilities and supplier-facing teams.
- Prepare the board or senior signatory for a more formal approval process and proposed accuracy declaration.
- Plan for mandatory government submission, fixed reporting deadlines and potential financial penalties for non-compliance.
