Modern slavery remains a global crisis, and it’s getting worse. An estimated 50 million people worldwide are living in modern slavery, including 28 million in forced labour and 22 million in forced marriage, according to the International Labour Organization. That number has risen sharply due to conflict, climate change, and the economic fallout from COVID-19. Governments and media are ramping up scrutiny: in December 2024, a BBC investigation revealed that UK supermarkets may be sourcing from suppliers linked to forced labour, while that same month, the EU’s forced labour ban came into effect, barring goods made with forced labour from entering the single market. Meanwhile, countries including Australia, France, Germany, Norway, and Switzerland already require companies to actively report on their efforts to combat forced labour.
In March 2025, the UK Home Office published a long-awaited update to modern slavery guidance in its Transparency in Supply Chains statutory guidance under the Modern Slavery Act. The refresh to the guidance is the first significant update in nearly a decade, offering businesses a much clearer picture of what meaningful disclosure looks like, even though the underlying legal duty remains unchanged.
With Parliament set to return in September, and fresh pressure mounting for reform, it’s time to revisit the March guidance, not because anything has changed legally since then, but because this guidance increasingly looks like a precursor to legislative change. While the law hasn’t changed, the direction of travel is clear, so now is the time for businesses to tune in.
The law hasn’t changed, but expectations have
The new guidance marks a notable shift in tone from the government. It moves beyond box-ticking and encourages companies to focus on effectiveness, not just process. It pushes for year-on-year improvement. It offers more structure, more clarity, and clearer expectations, especially for complex corporate groups. In short, it’s about what’s coming next.
Why this matters now: A September shake-up?
Here’s what’s changed since the guidance was published:
- In July 2025, the Joint Committee on Human Rights issued a major report calling for:
- Mandatory human rights due diligence
- Stronger civil liability for harm
- An import ban on goods linked to forced labour
The government must respond within 60 days, i.e., just after Parliament resumes in September.
- In March, the Business & Trade Committee warned that the UK risks becoming a “dumping ground” for goods linked to exploitation, and recommended mandatory modern slavery reporting with enforcement powers.
- The Independent Anti-Slavery Commissioner’s 2024–25 report, published in May, backed legislative reform, calling for a new modern slavery strategy, mandatory due diligence, and coordinated enforcement.
Taken together, these developments show that the political climate is shifting fast. And that March guidance? It’s likely the first step in a broader compliance overhaul.
The direction of travel: From transparency to accountability
For years, modern slavery compliance has been built on a model of transparency without teeth: Since the Modern Slavery Act came into force, compliance with the reporting duty has largely operated without active enforcement. While the law allows the Home Office to seek a court injunction against non-compliant companies, this power has never been used, and there are currently no direct financial or criminal penalties for failing to publish a statement.
But now, it looks like that’s changing.
The new guidance, and the political momentum behind it, suggest that the UK is finally moving closer to the EU model, where businesses are expected to conduct proper human rights and environmental due diligence, backed by enforcement powers and civil liability.
At the same time, broader legal reforms are tightening the net: the Economic Crime and Corporate Transparency Act (ECCTA) has already expanded corporate liability for fraud and other economic crimes committed by senior managers, while the Crime and Policing Bill proposes extending that same liability model to all criminal offences, potentially including modern slavery and labour exploitation. Prosecutors are increasingly focused on supply chain failures — and this combination of political pressure, updated guidance, and expanding legal frameworks signals a clear shift from voluntary transparency to real accountability.
What should businesses do now?
Even though the law hasn’t changed (yet) businesses should treat this as a signal to act, not wait. With the expectations around modern slavery reporting are shifting, here’s how to get ahead:
- Reassess your modern slavery statement
Does it reflect actual risk analysis, real-world impact, and year-on-year improvement? - Map your supply chain
Especially for goods linked to high-risk regions or industries. Be ready to demonstrate traceability. - Align internal teams
Procurement, legal, compliance, and sustainability should work together to deliver meaningful due diligence. - Engage suppliers meaningfully
Move beyond questionnaires. Think audits, training, and long-term relationship-building. - Look beyond the UK
If you operate internationally, start aligning with the EU’s Corporate Sustainability Due Diligence Directive (CSDDD)—it’s a preview of where the UK may be heading. - Get ahead of enforcement
Strengthen governance and controls as if the registry, penalties, and reporting requirements were already law, because they soon might be.
The Home Office’s modern slavery guidance may not carry the force of law yet, but it’s a clear warning shot.
As we head into the next parliamentary term, the direction of travel is clear — expectations are rising, scrutiny is intensifying, and the days of passive compliance are numbered. For businesses, this is the moment to move beyond the minimum and embed meaningful, proactive accountability into every stage of their supply chain.
