Modern Slavery Act: A Guide for UK Businesses
Modern Slavery Act: A Guide for UK Businesses
Last updated: 24 June 2026 | Author: VerdaScope Editorial Team
The Modern Slavery Act 2015 (MSA) introduced world-leading transparency requirements for UK organisations addressing forced labour supply chain risks. If you are researching Modern Slavery Act business obligations — whether as a large corporate, public sector buyer, or SME supplier — this guide explains who must comply, what a modern slavery statement must cover, and how to build credible modern slavery compliance without overclaiming.
Regulatory note: UK modern slavery legislation has been subject to parliamentary debate and proposed reforms. Requirements described here reflect the MSA 2015 Section 54 framework in force as of June 2026. Verify current law before relying on this guide for compliance decisions.
Direct Answer
Under the Modern Slavery Act 2015, commercial organisations supplying goods or services in the UK with annual turnover of £36 million or more must publish an annual modern slavery statement describing steps taken to prevent modern slavery in their business and supply chains. The statement must be approved by the board (or equivalent) and signed by a director. Failure to publish may result in civil proceedings for an injunction. The Act does not mandate a particular due diligence standard, but statements should reflect genuine supply chain slavery risk assessment and remediation — not boilerplate text.
Key Takeaways
- MSA 2015 Section 54 applies to organisations with UK turnover ≥ £36m that carry on a business or part of a business in the UK.
- A modern slavery statement must be published annually on your UK website with a prominent link from the homepage.
- Recommended content covers six areas: structure, policies, due diligence, risk assessment, training, and effectiveness — per Home Office statutory guidance.
- Public sector and large private buyers increasingly flow down expectations to smaller suppliers even below the threshold.
- Credible compliance requires integration with supply chain transparency and sustainable procurement — not a standalone HR document.
- Avoid absolute claims (“slavery-free supply chain”) unless supported by comprehensive, verified due diligence.
What Is the Modern Slavery Act 2015?
The Modern Slavery Act 2015 is UK legislation addressing modern slavery and human trafficking offences. For businesses, the most significant provision is Section 54 — Transparency in supply chains, which requires qualifying organisations to publish an annual slavery and human trafficking statement.
Modern slavery encompasses:
- Forced labour
- Debt bondage
- Human trafficking
- Child labour (where it constitutes slavery or exploitation)
- Domestic servitude
These risks exist globally, including in UK-based industries such as construction, agriculture, hospitality, and cleaning — not only offshore manufacturing.
Who Must Comply?
Mandatory reporting threshold
An organisation must publish a statement if it:
- Is a commercial organisation (body corporate or partnership carrying on business)
- Supplies goods or services
- Carries on a business or part of a business in the UK
- Has annual turnover of £36 million or more (including subsidiaries’ turnover in a group structure)
Turnover is assessed according to the Companies Act 2006 definition for companies. Groups may publish a single group statement or separate entity statements.
Who is not legally required (but may still be affected)
| Organisation | Position |
|---|---|
| SMEs below £36m | No mandatory statement — but may face customer due diligence requests |
| Public sector bodies | Not covered by Section 54 in the same way — but government has published its own modern slavery reporting guidance for central government |
| Charities | Covered if they meet commercial organisation test and turnover threshold |
| Overseas companies | Covered if they conduct business in the UK and meet turnover test |
Public sector procurement angle
Central government and many public buyers assess suppliers’ modern slavery statements and due diligence in tenders — especially for high-risk categories (uniforms, electronics, construction labour). See social value in procurement and sustainable procurement.
What Must the Modern Slavery Statement Include?
Section 54 does not prescribe mandatory content, but the Home Office statutory guidance recommends covering:
| Area | What to describe |
|---|---|
| 1. Organisation structure | Business model, sectors, countries of operation |
| 2. Supply chains | How supply chains work; high-risk categories and geographies |
| 3. Policies | Relevant policies (procurement, HR, whistleblowing, supplier code) |
| 4. Due diligence | Risk assessment processes; supplier onboarding and audits |
| 5. Risk assessment | Identified risks and how they are prioritised |
| 6. Training | Staff and supplier training on modern slavery |
| 7. Effectiveness | KPIs or measures showing what has been achieved |
| 8. Approval | Board (or equivalent) approval statement |
Statements may also explain steps taken during the financial year and plans for the next period.
Approval and signature requirements
The statement must be:
- Approved by the board of directors (or equivalent management body)
- Signed by a director (or designated partner for LLPs)
For LLPs, regulations specify signing arrangements. Partnerships outside LLP structures should seek legal advice on approval mechanics.
Publication requirements
- Publish on the organisation’s UK website
- Provide a link in a prominent place on the homepage (footer links are common)
- Government encourages publication within six months of financial year end
A central government registry for statements has been proposed in reform discussions — check gov.uk for current publication arrangements.
Compliance Workflow: Checklist
Annual cycle
| Step | Action | Owner |
|---|---|---|
| 1 | Confirm turnover threshold still met | Finance / legal |
| 2 | Update supply chain risk assessment | Sustainability / procurement |
| 3 | Review supplier audit and incident data | Procurement |
| 4 | Update policies and training records | HR / compliance |
| 5 | Draft statement with evidenced content | Sustainability + legal |
| 6 | Board approval | Company secretary |
| 7 | Director signature | Director |
| 8 | Publish on website | Communications / web |
| 9 | Archive previous statement | Compliance |
Due diligence activities (ongoing)
- Supplier code of conduct with forced labour prohibitions — see procurement policy template
- Questionnaires for high-risk suppliers — see sustainable sourcing guide
- Tier 1 mapping and targeted Tier 2 for labour-intensive categories
- Audit programme proportionate to risk (third-party ethical audits where justified)
- Whistleblowing channel for workers and suppliers
- Remediation protocols if violations identified
- Training for procurement, HR, and site managers
Link to supply chain transparency for mapping methodology.
High-Risk Categories and Geographies
Modern slavery risk is not uniform. UK organisations often prioritise:
| Category | Risk factors |
|---|---|
| Apparel and textiles | Labour-intensive production; subcontracting |
| Electronics | Migrant labour; complex Tier 2+ chains |
| Agriculture and food processing | Seasonal workers; gangmaster risks (UK) |
| Construction | Subcontracted labour; recruitment fees |
| Cleaning and facilities | Low wages; vulnerable workers |
| Mining and minerals | Forced labour reports in some regions |
Geographic risk varies by commodity — assess using credible sources (OECD, ILO, NGO reports) rather than assumptions.
Compliant vs Risky Approaches
Compliant characteristics
- Specific description of supply chain structure and risk tiers mapped
- Named policies with URLs or internal references
- KPIs such as % strategic suppliers assessed, audits completed, training hours
- Honest acknowledgment of gaps and improvement plans
- Board approval and director signature with date
- Integration with sustainable supply chain management
Risky characteristics
- Generic boilerplate copied from templates without customisation
- No board approval or signature
- Absolute assurance language without evidence
- Statement published late or not linked from homepage
- No connection between statement and actual procurement practice
- Claiming compliance while failing to investigate known alerts
Common Mistakes
| Mistake | Risk | Fix |
|---|---|---|
| Legal team drafts in isolation | Inaccurate supply chain content | Cross-functional input from procurement |
| Statement unchanged year-on-year | Suggests box-ticking | Report progress and new risks |
| No KPIs | Weak effectiveness section | Define measurable indicators |
| Ignoring UK domestic risk | Misses hidden labour abuse | Include UK subcontractor due diligence |
| Overclaiming remediation | Reputational damage if challenged | Describe actions taken and limitations |
| SME suppliers unprepared | Fails customer audits | Provide questionnaire guidance |
Relationship to Wider Sustainability Law
| Related area | Connection |
|---|---|
| Sustainable procurement | Contract clauses enforce labour standards |
| Social Value Act | Fair work themes in public tenders |
| ESG reporting | Social metrics and governance narratives |
| EU / UK due diligence reforms | Potential future mandatory human rights due diligence — monitor UK sustainability legislation |
SMEs Below the Threshold
If turnover is under £36m, you are not legally required to publish — but you may:
- Receive flow-down requirements from large customers
- Be asked for modern slavery policies in tenders
- Choose to publish voluntarily to demonstrate leadership
Practical SME steps:
- Adopt a one-page anti-slavery policy
- Map Tier 1 suppliers
- Add labour clauses to standard terms
- Train staff who manage high-risk outsourced services
Enforcement and Consequences
The Secretary of State may bring civil proceedings for an injunction requiring an organisation to comply with publishing duties. Reputational consequences from NGO rankings, media investigation, and customer termination can exceed direct legal penalties.
The Act creates criminal offences for perpetrators of modern slavery — separate from business reporting duties. Organisations discovering slavery indicators should follow Home Office guidance on reporting victims to appropriate authorities.
Writing an Effective Statement: Section-by-Section Tips
Organisation and supply chain structure
Name your sectors, geographies, and approximate supplier numbers. A table helps readers scan complexity:
| Element | Example disclosure |
|---|---|
| Sectors | Retail, wholesale, e-commerce |
| Tier 1 suppliers | ~450 globally; top 50 = 80% spend |
| High-risk categories | Apparel, electronics assembly, cleaning services |
| Countries | UK, Bangladesh, China, Vietnam, Poland |
Policies
List policies with dates and owners: procurement, HR, whistleblowing, grievance, supplier code. Link to public documents where available.
Due diligence and risk assessment
Describe your process chronologically: onboarding → periodic refresh → incident response. Reference tools (sustainable sourcing questionnaire, audit firms, Sedex).
Effectiveness measures
Examples of credible KPIs:
- % strategic suppliers completing labour questionnaire
- Number of ethical audits completed in reporting year
- Whistleblowing cases investigated (without compromising confidentiality)
- Training completion rate for procurement staff
- Time to close corrective actions
Avoid claiming “zero incidents” unless you have comprehensive visibility — limited visibility should be acknowledged.
Group Structures and Subsidiaries
Corporate groups may publish:
- One group statement covering all UK entities — common for efficiency
- Separate statements per subsidiary — where brands require distinct accountability
Parent companies should ensure subsidiaries meet turnover tests in aggregate where legislation applies to group operations. Finance and company secretarial teams should confirm structure with legal counsel annually.
Training Programme Outline
Effective modern slavery training covers:
| Audience | Content |
|---|---|
| Board and executives | Legal duties, reputational risk, governance expectations |
| Procurement | Red flags in tenders, audit review, contract clauses |
| HR and recruitment | Safe recruitment, worker vulnerability indicators |
| Operations / site managers | Subcontractor oversight, reporting channels |
| All staff | How to raise concerns; internal whistleblowing route |
Refresh training when policies change or after incidents. Record attendance for effectiveness sections of statements.
Red Flags in Supply Chains
Train teams to escalate indicators including:
- Recruitment fees charged to workers
- Retention of identity documents
- Subcontracting without disclosure
- Unusually low pricing inconsistent with fair wages
- Worker accommodation provided by employer under poor conditions
- Lack of written contracts or payslips
No single indicator confirms modern slavery — but patterns warrant immediate investigation and possible suspension of orders pending findings.
Frequently Asked Questions
What is the Modern Slavery Act business threshold?
UK turnover of £36 million or more for commercial organisations supplying goods or services and conducting business in the UK.
What is a modern slavery statement?
An annual document describing steps the organisation has taken to ensure slavery and human trafficking are not occurring in its business or supply chains.
Who must sign the statement?
A director (for companies) or designated partner (for LLPs), after board or equivalent approval.
Where must it be published?
On the organisation’s UK website with a prominent homepage link.
How often must it be updated?
Annually, aligned to the financial year. Government guidance recommends publication within six months of year end.
Does the Act require supplier audits?
Not explicitly — but due diligence described in statements should be credible and proportionate to identified risks.
What is MSA 2015?
Common abbreviation for the Modern Slavery Act 2015.
How does this relate to supply chain slavery?
Section 54 focuses on transparency about addressing supply chain slavery risks — not certifying chains as slavery-free.
Are public sector bodies covered by Section 54?
Commercial organisations within the public sector may be covered if they meet the commercial organisation test. Wider public sector reporting follows separate government guidance.
What reforms are proposed?
UK Parliament has debated strengthening enforcement, central registry, and civil penalties. Monitor legislation.gov.uk and gov.uk for updates — requirements may change.
Next Steps
- Build transparency — supply chain transparency
- Supply chain programme — sustainable supply chain management
- Procurement integration — sustainable procurement guide
- Supplier tools — sustainable sourcing guide
Sources and Further Reading
- Modern Slavery Act 2015
- Home Office — Transparency in supply chains statutory guidance
- Home Office — Modern slavery: how to identify and report victims
- Modern Slavery Helpline
This article is for general guidance only. It does not constitute legal advice. Organisations should obtain qualified legal counsel for compliance with the Modern Slavery Act 2015 and any subsequent reforms.