The Modern Slavery Act at Ten: A Landmark Law Under Scrutiny
The UK Modern Slavery Act 2015 was enacted on 26 March 2015 as a groundbreaking piece of legislation aimed at eradicating forced labor, human trafficking, and exploitation from UK businesses and their supply chains. Section 54 of the Act requires all commercial organizations operating in the UK with an annual turnover of £36 million or more to produce and publish an annual modern slavery statement setting out steps taken to prevent slavery and human trafficking in their operations and supply chains. At the time of its passage, the Act was considered world-leading. However, ten years on, the landscape has changed dramatically. In January 2024, the House of Lords appointed a select committee to conduct a post-legislative review of the Act's implementation, impact, and effectiveness. The committee published its report in October 2024, concluding that while the Act had been effective when it came into force, it could no longer be considered world-leading, as best practice and global legislation had moved on. The report highlighted that in the decade since the MSA received Royal Assent, the world's concept of supply chain transparency reporting had been transformed, leading to widespread criticism that the UK's reporting regime had not kept pace. In particular, there had been poor monitoring and enforcement of compliance requirements, resulting in significant inconsistency in the quality and effectiveness of modern slavery statements across organizations.
In response to Parliamentary pressure, the UK Home Office published its most significant update to supply chain transparency guidance since 2017, raising the bar for how organizations must identify and report modern slavery risks.
In response to the House of Lords committee recommendations, the UK Home Office published updated statutory guidance titled Transparency in Supply Chains (TISC): A Practical Guide on 25 March 2025 — the most significant refresh of the guidance since it was first issued almost ten years ago. The guidance introduces strengthened expectations for how organizations required to produce an annual modern slavery statement can embrace the letter and spirit of Section 54 of the Modern Slavery Act 2015 and produce a robust disclosure. While compliance with the guidance remains advisory rather than mandatory and does not change the core legal requirements of the Act, it provides businesses with clearer advice and materially higher expectations on how to address and report on modern slavery risks. A key structural change in the updated guidance is the introduction of a two-tiered disclosure framework. The guidance categorizes the level of detail expected in modern slavery statements as either Level 1 (basic or foundational) or Level 2 (enhanced or more comprehensive). New reporters are expected to focus on achieving Level 1 benchmarks, while more seasoned organizations are strongly encouraged to progress toward Level 2, demonstrating continuous improvement and deeper engagement year on year. The guidance also significantly expands the definition of supply chain, clarifying that it encompasses not only a company's primary value chain — the goods sold or services delivered — but also the secondary value chain covering support activities such as HR, catering, and cleaning, as well as the labor supply chain, meaning how and from where workers are recruited. Importantly, the updated guidance underscores that failing to identify any risks or incidents of modern slavery may itself reflect insufficient due diligence rather than a genuine lack of exposure, pushing organizations toward more rigorous self-examination.
Organizations face significant legal, financial, and reputational exposure for failing to meet the Act's transparency obligations, with enforcement tools available to the Home Office under Section 54.
Under the updated guidance, organizations must map their supply chains, identify risk hotspots using the latest guidance, and engage both internal teams and external stakeholders such as NGOs, trade unions, and peers. Statements must be approved by the board or equivalent governing body and signed by a director or designated partner, and must be posted prominently on the organization's website. Organizations are also encouraged to upload their statements to the government's Modern Slavery Statement Registry, which already contains statements from over 12,000 organizations. Failure to comply with Section 54 carries serious legal consequences. The Secretary of State may bring civil proceedings against non-compliant businesses, which could result in an injunction and potentially an unlimited fine for contempt of court. Beyond legal penalties, businesses that fail to address modern slavery risks face reputational damage, loss of consumer trust, exclusion from commercial supply chains and government procurement tenders, and increased insurance premiums. The guidance also places modern slavery obligations within their broader international context, noting the potential impact of the EU's Corporate Sustainability Due Diligence Directive (CSDDD), companies' commitments under the UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises. With global regulatory momentum increasing, the October 2024 House of Lords report went further still, recommending that the UK government enact legislation requiring companies to undertake mandatory modern slavery due diligence in their supply chains and take reasonable steps to address problems identified — signaling that even more onerous requirements may be forthcoming.
As supply chain due diligence laws tighten globally, the UK's modernized guidance aligns with a broader international movement toward mandatory human rights accountability across corporate supply chains.
The UK's enhanced approach to modern slavery compliance does not exist in isolation. Across the globe, governments are moving beyond voluntary transparency toward mandatory due diligence. The EU Forced Labour Regulation entered into force in December 2024 and will apply to EU member states from December 2027, prohibiting the import, sale, or export of any product made with forced labour, covering raw materials, component parts, and every tier of the supply chain. Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act came into force on 1 January 2024, introducing broader mandatory reporting requirements and penalties for non-compliance. The US Uyghur Forced Labor Prevention Act similarly requires companies to conduct supply chain due diligence to avoid goods being stopped at the US border. As this international survey demonstrates, the UK's existing reporting regime and domestic law are increasingly out of step with comparable jurisdictions' treatment of supply chain transparency and due diligence. The updated Home Office guidance is widely viewed as a step toward alignment with these global benchmarks, with analysts noting that complying with the new guidance provides a solid foundation for meeting existing and incoming international requirements. For businesses operating across multiple jurisdictions, the UK, Australian, and Canadian governments have also collaborated to produce an optional international reporting template designed to reduce the administrative burden for organizations subject to modern slavery reporting requirements in all three countries, supporting the development of a single report that meets all three frameworks.
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