Our recent webinar on modern slavery compliance and the proposed reforms under the Immigration and Asylum Bill generated a large number of thoughtful and practical questions. Many focused on the £36 million threshold, group structures, supplier due diligence, training and how organisations should prepare while the legislation is still moving through Parliament.
We were unable to answer every question during the session, so we have brought together responses to the most common issues below. These answers distinguish between the current requirements under section 54 of the Modern Slavery Act 2015, the December 2025 Home Office guidance and the changes proposed under the Bill.
The central message is that organisations do not need to wait for the final legislation before improving their approach. A proportionate, evidence-based compliance programme will place businesses in a stronger position under both the current regime and any future reforms.
Listen again to the modern slavery: new legislation announced webinar.
What should smaller suppliers do if they are below the £36 million threshold?
They are not legally required by either the Modern Slavery Act 2015, or the proposals in the Immigration and Asylum Bill. So from a compliance perspective they do not have an obligation to prepare or publish a modern slavery and human trafficking statement. However, they may still be asked questions by larger customers or public-sector clients, and probably will be if they have larger companies in their value chain.
So I would keep it simple. Have a basic modern slavery policy and know who owns the issue internally. Train relevant staff. Keep records of supplier checks and have a clear route for raising concerns. You may not need a long statement or a complex system, but you should be able to answer customer questions with something more than “we do not think this applies to us”.
Who should own modern slavery compliance internally?
There should be one clear owner for the statement, that will often sit with legal, compliance, ESG. But that person cannot do it alone. They need to work across the business so having a board sponsor can be helpful, and making this clear this is a high priority for the business.
So the best setup is one named owner, with named contacts in each key team. Otherwise everyone assumes someone else has checked it.
Where must a modern slavery statement currently be published: on the organisation’s website, in its annual report and accounts, or both? Would this change under the Immigration and Asylum Bill?
Under the current Modern Slavery Act 2015, an in-scope organisation with a website should publish its annual modern slavery statement on that website and include a prominent link to it on the homepage. Where the organisation has no website, it must provide a copy to anyone who makes a written request, normally within 30 days.
There is no general requirement under section 54 to include the statement in the organisation’s annual financial statements or annual report. Some organisations choose to refer to it there as a matter of governance or good practice, although that does not replace the website publication requirement.
Under the proposed Immigration and Asylum Bill, website publication and the prominent homepage link would remain. The Bill would also introduce a more formal requirement for the statement, or a link to it, to be submitted electronically to the Secretary of State in a prescribed form. It would need to be published and submitted as soon as reasonably practicable after the end of the financial year and, in any event, within six months.
In practical terms, the Bill would add a formal government filing requirement. It would not move the statement into the annual accounts or make the annual report the primary place of publication.
Will the proposed 1% penalty be calculated using the turnover of the particular legal entity in breach, or the turnover of its ultimate parent or wider corporate group?
The Bill does not simply refer to the worldwide turnover of the ultimate parent company. As currently drafted, the percentage would be calculated by reference to the “total turnover” of the commercial organisation on which the penalty is imposed. New section 54ZD would use the same method of determining total turnover as the existing section 54 regime.
Under the existing regulations, an organisation’s total turnover comprises its own turnover plus the turnover of its subsidiary undertakings.
This suggests that:
- Where the penalised organisation is a UK subsidiary, the calculation would normally include that subsidiary and any subsidiaries beneath it. It would not automatically include the turnover of its parent or sister companies.
- Where the penalised organisation is the parent undertaking, its total turnover would include its subsidiaries and could therefore amount to group-wide turnover.
There is still some uncertainty for group statements. The Bill would allow a parent undertaking to certify a statement relating to a subsidiary, and a single statement may cover several in-scope group companies. The primary legislation does not fully explain how liability and the turnover calculation would operate where several legal entities are covered by one deficient statement. We may get more of that in secondary legislation or guidance from the Home Office.
Overall, the penalty appears to attach to the turnover of the particular commercial organisation in breach, including its subsidiaries, rather than automatically to the ultimate global parent. But the final enforcement regulations and guidance will need to clarify how this works for consolidated group statements.
If this will be law by end of the year and has to be executed on by companies in 2027 and reflected in the 2027 statement which is published in 2028. Correct?
Broadly, yes, that is a sensible planning assumption, although it is not yet a confirmed legal timetable.
The Bill is still at Commons Committee stage. The Public Bill Committee is due to begin detailed scrutiny on 10 September 2026 and is currently expected to report by 3 November. Royal Assent by the end of 2026 is therefore possible, although the Bill would still need to complete its remaining Commons stages and pass through the House of Lords.
More importantly, the corporate reporting provisions would not automatically take effect on Royal Assent. The Bill allows the Secretary of State to bring provisions into force on appointed dates, use different dates for different requirements and make transitional arrangements. The electronic submission and penalty regimes will also require further regulations.
So we cannot yet say definitively that the first mandatory enhanced statement will be the 2027 statement published in 2028. The commencement regulations might apply the requirements only to financial years beginning after a specified date, or provide a different transition for companies whose financial years are already underway.
Is the £36 million turnover threshold likely to change under the Immigration and Asylum Bill, for example by being reduced so that more businesses fall within scope?
At present, there is no proposal in the Bill to reduce the £36 million threshold for commercial organisations. The Bill retains the existing section 54 population and concentrates on strengthening the content, governance, filing and enforcement requirements.
The current £36 million threshold therefore remains the working assumption. It continues to appear in current government guidance, and the Bill as introduced does not replace it with a lower figure.
A reduction remains legally possible in the future because the threshold is prescribed through regulations rather than permanently fixed in the primary Act. However, there is currently no clear government indication that it intends to use this Bill to lower it. The more immediate expansion is to qualifying public authorities, whose budget threshold will be prescribed separately.
Our company works extensively with public-sector organisations. How is the Immigration and Asylum Bill likely to affect public procurement and the information suppliers are expected to provide?
Yes, it is likely to affect public-sector procurement, although primarily through stronger supplier assurance, due diligence and contract management, rather than creating an entirely new procurement process.
The Bill would bring qualifying public authorities into the statutory modern slavery reporting regime. Those authorities would need to explain their supply chains, identify areas of risk, describe the due diligence undertaken and show how their controls are working. Public-sector buyers will therefore need better evidence from suppliers in order to support their own statements and accuracy declarations.
For central government departments, executive agencies, non-departmental public bodies and NHS bodies, this would build on requirements that already exist. Procurement Policy Note 009 currently requires those organisations to identify and manage modern slavery risks in new procurements and existing contracts. For high-risk procurements, it also requires supply-chain information and supports enhanced due diligence and use of existing exclusion grounds.
Will submission of the modern slavery statement to the government’s central registry become mandatory?
Yes, under the Bill’s current drafting, electronic submission to the Secretary of State would become mandatory, alongside publication on the organisation’s website. The Bill does not yet confirm whether this will use the existing central registry in exactly its current form, as the submission process will be set through regulations. At present, registry submission remains encouraged rather than legally required.
These changes are still proposals. When are we likely to know whether they have been approved, and when they will take effect?
They are slightly more than proposals since this is included in legislation which is currently before Parliament. The Bill has passed its second reading, although none of the proposed corporate reporting changes is law yet. The Public Bill Committee will begin detailed scrutiny on 10 September 2026 and is expected to report by 3 November. The Bill must then complete its remaining Commons stages, pass through the House of Lords and receive Royal Assent. Final approval could come in late 2026 or early 2027, although there is no guaranteed date.
Royal Assent will not necessarily make the modern slavery provisions effective immediately. The Bill allows the Secretary of State to commence different provisions on different dates and introduce transitional arrangements. Further regulations will also be needed for areas such as electronic submission and financial penalties.
The practical timetable should become clearer after the Committee stage in autumn 2026, with certainty only once the final Act, commencement regulations and supporting guidance are published. For planning purposes, organisations should prepare during 2027, while recognising that the first financial year covered by the new requirements has not yet been confirmed.
If our annual turnover is below £36 million, are we required to publish a modern slavery statement, and what should we still do to manage modern slavery risk?
If the organisation’s total turnover, including relevant subsidiaries, is below £36 million, it is generally outside the section 54 reporting duty and does not have to publish a statement. The Bill, as drafted, does not change that threshold for commercial organisations.
However you may be part of the supply chain of entities who are covered, and therefore will be asking you about your own modern slavery efforts as part of their own supply chain due diligence. A proportionate approach would include assessing where modern slavery risk could arise, carrying out appropriate checks on higher-risk suppliers, training relevant staff and maintaining a clear process for escalating concerns. Customers and public-sector bodies may also require policies, questionnaires or supporting evidence through procurement and contract terms, even where the statutory reporting duty does not apply.
If our UK subsidiary has turnover below £36 million, while the global parent or group exceeds £36 million, must the UK subsidiary publish a modern slavery statement?
Not automatically. The section 54 test applies to each legal organisation. The UK subsidiary would be directly required to publish only if its own total turnover, including the turnover of any subsidiaries beneath it, reaches £36 million and it meets the other conditions. The turnover of its parent and sister companies is not automatically added to the UK subsidiary’s turnover.
The overseas parent may have its own reporting duty if it supplies goods or services, has total turnover of at least £36 million and is considered to carry on business, or part of a business, in the UK. Merely owning a UK subsidiary does not establish this by itself. Where the parent is in scope, it may publish a group statement covering the UK subsidiary, even where that subsidiary is not independently required to report.
The group should therefore assess the UK nexus and turnover of each legal entity, rather than relying only on UK revenue or overall group revenue.
We currently have a modern slavery policy, although we have not previously published a statement. As we are approaching the £36 million threshold, what standard should we aim for in our first reporting year?
Aim for a credible, evidence-based first statement, rather than trying to present a fully mature programme immediately. It should cover all six areas recommended by the Home Office: structure and supply chains, policies, risk assessment, due diligence, training and measures of effectiveness.
During the first year, carry out a documented risk assessment, identify the higher-risk suppliers and labour arrangements, apply proportionate due diligence, train relevant staff and retain evidence of what was done. The statement should explain what you found, what action you took and where work remains in progress. It is acceptable to acknowledge gaps and set realistic priorities for the following year. Generic claims or statements that the business has “zero tolerance” are less useful than an honest account of the controls actually implemented.
Given the proposed reforms, I would also structure the first statement so that it broadly follows the new Bill’s expected reporting model. This should reduce the amount of reworking required later.
If our organisation is below the £36 million turnover threshold but chooses to publish a modern slavery statement voluntarily, will the proposed changes still affect us?
The proposed changes would not directly apply unless the organisation falls within scope. However, if you already publish a statement, it would be sensible to continue and align it as closely as possible with the new format, particularly around risk assessment, due diligence, training, effectiveness and evidence.
Publishing voluntarily can create an expectation among customers, suppliers and public-sector buyers that the statement is reliable and kept up to date. Once that expectation exists, an inconsistent or weak statement may create reputational or procurement risk even where there is no statutory breach. Organisations outside the legal threshold are already likely to face requests for supplier questionnaires and evidence of how modern slavery risks are managed.
The safest approach is therefore to treat the statement seriously, support each claim with evidence and follow the proposed structure as far as proportionate. A stronger statement explains what the organisation actually did, what it found and what still needs improvement.
For the purposes of the £36 million threshold under section 54, should we consider only the UK entity’s turnover, or the consolidated worldwide turnover of the wider corporate group?
The test applies to the particular commercial organisation being assessed. Its “total turnover” includes its own worldwide turnover and the turnover of its subsidiary undertakings, including subsidiaries operating wholly outside the UK. It does not automatically include the turnover of its parent company or sister companies.
Therefore, if the relevant organisation is a UK subsidiary, assess that subsidiary and any entities beneath it. If the overseas parent itself carries on business, or part of a business, in the UK, it should be assessed separately. Its turnover calculation could include all its subsidiaries and therefore be equivalent to consolidated group turnover. The fact that most of the revenue is generated outside the UK does not remove the obligation once the relevant organisation has a demonstrable UK business presence and meets the other statutory conditions.
A group statement may cover several in-scope companies, although the group should first document which individual legal entities actually meet the statutory test.
How should a business respond if it suspects that workers employed by a current cleaning contractor may be experiencing exploitation or modern slavery?
Treat the concern as a safeguarding and supplier-risk issue. Record the specific warning signs, escalate the matter promptly to compliance, legal, procurement or the appropriate safeguarding lead, and avoid confronting the suspected exploiter or questioning workers in a way that could place them at greater risk.
Cleaning is recognised as a higher-risk outsourced service. The business should conduct enhanced due diligence into areas such as wages, working hours, recruitment fees, subcontracting, labour providers, retention of identity documents and whether workers can raise concerns safely. Any worker engagement should be confidential and preferably handled by trained staff or an independent specialist.
The response should prioritise worker safety, prompt investigation and remediation. Immediate termination may sometimes increase the risk to affected workers, so the organisation should consider a corrective action plan, closer monitoring or responsible disengagement depending on the seriousness of the findings and the supplier’s cooperation.
Where someone appears to be in immediate danger, call 999. Other suspicions can be reported to the police on 101 or confidentially to the Modern Slavery Helpline.
What are the main differences between the December 2025 TISC guidance and the proposed reporting requirements under the Immigration and Asylum Bill?
Very few. The 2025 guidance already expects risk-based due diligence, meaningful training, remediation, KPIs and evidence of effectiveness. It also recommends publication within six months and voluntary upload to the government registry.
The Bill would make many of those expectations legally mandatory. Statements would have to follow prescribed content, identify risks or explain why no assessment was undertaken, address supply-chain training where reasonably available and include formal certification and an accuracy declaration. It would also bring qualifying public authorities into scope, make electronic government submission mandatory, place the six-month deadline in legislation and introduce financial penalties.
Organisations already following the 2025 guidance in a meaningful way are well placed for the proposed regime. They should largely be building on their existing approach by formalising processes, strengthening the supporting evidence and meeting the new approval and submission requirements.
If a supplier repeatedly refuses to provide modern slavery information, what risk do we face if we continue the relationship?
Refusal does not automatically mean modern slavery is occurring, although repeated non-engagement is a red flag. It limits your ability to assess the supplier and makes it harder to justify continued reliance on them, particularly where the supplier operates in a higher-risk sector or uses subcontracted, migrant or agency labour.
The main risk is that, if concerns later emerge, the organisation may struggle to show that it took reasonable and proportionate steps. You should record the requests made, escalate the supplier’s refusal, consider enhanced checks and review any contractual audit, remediation or termination rights. Continued business may still be defensible in some cases, although the decision and any additional controls should be clearly documented.
What should we do when a supplier denies any modern slavery risk, although credible external reporting suggests that the risk may exist within its sector or supply chain, for instance Chinese electric vehicles (EVs)?
A supplier’s denial should not close the assessment. Credible adverse reporting is a risk indicator rather than proof against that particular supplier, although it means a general assurance is unlikely to be sufficient.
For Chinese EVs, there are documented concerns about forced-labour exposure in automotive supply chains, particularly through aluminium and lower-tier components. A US Senate investigation also found that major automakers had used parts produced by a supplier prohibited under US forced-labour controls.
The buyer should therefore seek evidence that tests the supplier’s answer, such as supply-chain mapping, the origin of key materials and components, subcontractor information, chain-of-custody records and credible independent audit findings. Supplier certifications alone may not be adequate where risk exists several tiers below the manufacturer.
If the evidence remains incomplete or inconsistent, record the unresolved risk, escalate it and consider enhanced monitoring, contractual remediation or restricting further purchases. Continuing without addressing credible contrary information would make it difficult to demonstrate meaningful due diligence. Where the risk cannot be adequately reduced or verified, the organisation should consider responsible disengagement.
What is the legal status of the Home Office Transparency in Supply Chains statutory guidance?
The guidance is the current official Home Office guidance under section 54(9) of the Modern Slavery Act 2015. The latest version was updated on 1 December 2025 and remains the operative guidance for organisations complying with the existing law.
Although described as “statutory guidance”, it does not make every recommendation a separate legal requirement. The Act remains the primary legal obligation. The guidance explains how the Home Office expects organisations to comply with both the letter and spirit of section 54, including areas such as publication within six months and coverage of the six recommended reporting categories.
The proposed Bill would place several of those expectations directly into legislation. Once those provisions are finalised and commenced, the guidance will probably need to be revised or replaced. Until then, organisations should continue following the 2025 guidance while preparing for the more prescriptive proposed requirements.
Should modern slavery training be provided to all employees, or only to those involved in supplier onboarding and due diligence?
A proportionate, tiered approach is best. All employees should receive basic awareness covering common warning signs and how to report concerns. More detailed, role-specific training should be provided to procurement and supplier-management teams, as well as relevant staff in HR, recruitment, facilities, operations, legal and compliance.
The 2025 Home Office guidance expressly recognises training for the whole organisation while expecting content to be tailored to different roles and responsibilities. Even employees who rarely encounter modern slavery risk may benefit from knowing what to recognise and where to escalate it.
The Bill would require the statement to describe training provided to employees and, where reasonably available, within the supply chain. It does not currently prescribe identical training for every colleague, so the depth and frequency should reflect each role’s exposure to risk.
