Why it matters
Australia's current Modern Slavery Act requires entities with at least A$100 million in annual consolidated revenue to publish annual statements about modern slavery risks.
The proposed reforms would raise the stakes considerably. Modern slavery compliance would no longer be primarily about publishing a report. Companies would need evidence that their risk controls actually work.
Penalties, a "reasonable steps" defense, and stronger enforcement tools are on the table.
Under the government's proposed crackdown:
The fine print: The size of the penalties, and exactly what qualifies as reasonable steps, has not been decided.
The reforms remain under development and are not yet enacted into law. But the direction is unmistakable: disclosure alone will not be enough.
Statements haven't reduced exploitation — and now trade pressure is compounding the risk.
Since 2019, more than 17,000 modern slavery statements covering over 27,000 businesses have been submitted to Australia's public registry.
Yet a 2023 review found no hard evidence that the law had produced meaningful change for people experiencing modern slavery.
Translation: More statements have not necessarily meant less exploitation. That's not good.
The proposed duty is designed to close that gap by shifting the focus from what companies say to what they can prove they did.
Australia is also facing international pressure. The United States has proposed additional tariffs of up to 12.5% on imports from economies it considers insufficiently active against forced-labor goods. Countries with stronger forced-labor controls may qualify for a lower proposed rate.
The bigger picture: Human rights risk is becoming trade risk. Companies that cannot trace their supply chains may face more than reputational damage. They could encounter penalties, market-access restrictions and higher import costs.
Four actions to start now — and how FRDM covers them without another questionnaire.
Waiting for the final definition of "reasonable steps" is risky. Strong due diligence takes time to build.
Start with four actions:
An annual questionnaire isn't going to work anymore.
FRDM transforms basic supplier data into multi-tier supply chain intelligence—without waiting for every supplier to complete another questionnaire.
Teams can use FRDM to:
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