UK Government proposes changes to modern slavery transparency regime

Businesses subject to UK modern slavery reporting would be mandated to provide more information in their modern slavery transparency statement, if proposed changes to the Modern Slavery Act 2015 (the MSA 2015) included in the Immigration and Asylum Bill are enacted. 

In this blog, we set out the key aspects of the proposed changes, how this approach compares with current modern slavery reporting regimes internationally, and practical steps that may be required by in-scope organisations. 

While the proposed changes mark a clear move toward increased transparency through mandatory content requirements, they remain relatively modest compared to more substantive obligations in relation to forced labour being adopted in many other jurisdictions.

The current UK regime versus the proposed changes: at a glance 

Section 54 of the MSA 2015 currently requires certain large commercial organisations with a qualifying UK business presence (whether or not UK-incorporated) to publish an annual slavery and human trafficking statement (a Modern Slavery Statement). 

While both the MSA 2015 and statutory guidance (the Transparency in Supply Chains Statutory Guidance from the Home Office) suggest a broad range of voluntary content for inclusion in Modern Slavery Statements, and encourage “clear, detailed and informative statements”, currently, the legally mandated content required to be included in the statement is extremely narrow. In particular, it does not require organisations to address the existence of modern slavery within their supply chains nor the effectiveness of any measures to manage this risk. The proposal for expanded mandatory content of Modern Slavery Statements, set out further below, will mandate topics for disclosure, including in relation to effectiveness of management and oversight. 

The proposal also includes an expanded penalty regime, which appears to respond to historic criticism that the existing regime lacks effective enforcement measures (see our blog on the UK Parliament’s report calling for reform to Forced Labour laws, here). The proposed changes would increase enforcement risk for in-scope organisations.

The table below provides a snapshot of the key differences between the existing regime and proposed new approach, on a topic by topic basis. 

Topic	Current position under the  MSA 2015	Proposed changes in the Immigration and Asylum Bill
Mandatory content of Modern Slavery Statement	Limited mandatory specific content The MSA 2015 only requires that a Modern Slavery Statement include (i) the steps taken during the financial year to ensure slavery and human trafficking is not taking place in the organisation’s supply chains and any part of its own business, or (ii) that the organisation has taken no such steps.  The MSA 2015 also sets out substantive content that may be included, but this is voluntary.	Increased scope of mandatory content Prescribes detailed requirements for the content of a Modern Slavery Statement, including in relation to: The entity’s structure, operations and supply chains Steps taken to identify and mitigate against the risk of slavery and human trafficking Policies, due diligence processes and training adopted in relation to slavery and human trafficking Effectiveness of the steps taken
Approval process	Senior approval and signature A Modern Slavery Statement must be approved and signed by an appropriate senior body and person. For companies, the board of directors must approve the statement, and it must be signed by a director.	Declaration of accuracy In addition to the existing approval requirements, Modern Slavery Statements would be required to contain a declaration by its individual signatory that the statement is accurate to the best of their knowledge and belief.
Publication deadline	No prescribed timeline The MSA 2015 does not prescribe any time limit. Statutory guidance suggests that Modern Slavery Statements should be published as soon as possible after the end of the organisation’s financial year, and at most, within 6 months after the end of that year.	ASAP, with a 6 month longstop The proposal would formalise the approach currently recommended in the statutory guidance, to require Modern Slavery Statements to be published as soon as reasonably practicable after the end of the financial year and, in any event, within 6 months.
Where to publish	Publication on website  If the organisation has a website, the Modern Slavery Statement must be published on the website with a link in a prominent place on the homepage. If the organisation does not have a website, a copy must be provided to anyone who makes a written request for one, within 30 days. There is also a voluntary option for organisations to upload their statements to a registry.	Potential additional requirements A statutory power would be given to the Secretary of State, to introduce regulations in the future requiring the electronic submission of Modern Slavery Statements (or the website link to them) through a Government-coordinated mechanism.
Penalties	Limited enforcement  The Secretary of State could enforce non-compliances with Modern Slavery Statement obligations by seeking injunctions via civil proceedings, but this is untested. In the unlikely scenario that an injunction was sought and granted and an organisation failed to comply with it, it would be in contempt of court, punishable by an unlimited fine.	Financial penalties New provisions would enable the Secretary of State to make regulations imposing a direct financial penalty for failure to comply with Modern Slavery Statement obligations without “reasonable excuse”. Any such financial penalty would not be permitted to exceed the higher of: (a) 1% of total turnover (for commercial organisations) or total budget (for public authorities), or (b) GBP 1 million.
Coverage of public sector	Focused on commercial organisations Modern Slavery Statement obligations are not imposed on public sector organisations.	Extends to public authorities  Modern Slavery Statement obligations would extend to apply to public authorities that meet certain budget thresholds – excluding the Security Service, Secret Intelligence Service and Government Communications Headquarters.

A step toward increased transparency, but short of substantive anti-slavery obligations 

While the proposed changes represent a clear movement in favour of requiring increased transparency on modern slavery, the changes do not respond to calls to enhance substantive protections against modern slavery. 

For example, a 2025 Parliamentary report on forced labour by the Joint Committee on Human Rights called for various ambitious reforms, including mandatory human rights due diligence duties for business, a civil right for survivors to claim against companies and a comprehensive import ban – see our previous blog here for further details. While the Government’s response to this report largely agreed with the recommendations, the Government has not proposed policy and legislative changes to implement these measures.

Likewise, the UK’s Independent Anti-Slavery Commissioner proposed a model legislative framework in December 2025, proposing, among other things, to: establish responsibility of commercial organisations and public undertakings for serious human rights harms, and to provide penalties and civil liability; prohibit forced labour products; and replace section 54 of the MSA 2015 with reporting and disclosure provisions on human rights. The Commissioner’s report notes that legislation is needed to align with the approach in many other jurisdictions (e.g. through the European Union Corporate Sustainability Due Diligence Directive) to avoid the UK becoming a “dumping ground” for goods tainted by forced labour, undercutting responsible businesses in the UK. 

The United Nations Committee on Economic, Social and Cultural Rights 2025 Periodic Report also noted concern about the absence of a comprehensive regulatory framework for human rights due diligence in the UK.

It is worth noting that whilst the Government has not brought forward substantive measures, a private members’ bill was introduced in June in the House of Lords (the “Commercial Organisations and Public Authorities Duty (Human Rights and Environment) Bill”). The Bill seeks to introduce an obligation to conduct human rights and environmental due diligence and require public reporting on the fulfilment of the due diligence obligations, among other things. The Bill also proposes civil liability, director liability and enforcement penalties. The Bill, if enacted, would establish a regime that is more similar in nature to the European Union’s Corporate Sustainability Due Diligence Directive. A similar but less detailed Bill was introduced in 2023, however it was not taken beyond the second reading. 

What this means for you

The second reading of the Immigration and Asylum Bill in the House of Commons is currently scheduled for 13 July. If these proposed changes are adopted, the key takeaways are that:

• If you are currently publishing Modern Slavery Statements that include only the minimum detail required, your approach will likely need to be reviewed and enhanced, and you may need to expand your data-gathering and governance measures accordingly.
• Boards should be aware of the increased accountability for Modern Slavery Statements, as well as the risk of penalties for non-compliance (after regulations contemplated by the Bill are established).
• There are likely to be greater modern slavery-related obligations applicable in other jurisdictions, so the development of a comprehensive strategy for cross-jurisdictional compliance is recommended. 

If you are currently using the optional International Reporting Template prepared by the UK, Australian and Canadian Governments (available here) for your Modern Slavery Statement, it may be helpful to note that the template already includes the broader, voluntary scope of disclosures suggested by the UK MSA 2015. Accordingly, a Modern Slavery Statement in this template form may be sufficient to meet the expanded disclosure requirements proposed by the Immigration and Asylum Bill. That said, if the Bill does become law, it would be advisable to monitor Home Office announcements for any potential updates to this voluntary reporting template.

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