Proposed amendments to the corporate transparency requirements in the UK Modern Slavery Act 2015 (the "Act") include the introduction of mandatory content requirements for the statement, declaration of statement accuracy from signatories and the possibility of stringent financial penalties for non-compliance with the duties in the Act. 

Background

On 30 June 2026, Home Secretary Shabana Mahmood introduced the Immigration and Asylum Bill (the "Bill") to Parliament. Whilst the Bill primarily focuses on asylum and immigration, it also proposes significant amendments to the Act, which include strengthening the regime under section 54 of the Act which currently requires commercial organisations with a global turnover of £36 million or more to publish an annual slavery and human trafficking statement. At present, the statement must disclose the steps, if any, taken by the commercial organisation. Section 54 is not prescriptive as to the information that should be included in relation to those steps. Disclosure of any due diligence the organisation undertakes to identify and address modern slavery risk is not obligatory, and there are no sanctions for non-compliance.

The scope of section 54, and indeed the wider modern slavery regime, has been widely criticised, including in the December 2025 report of the UK Independent Anti-Slavery Commissioner ("IASC"). The IASC noted in her report that since the "Act relies on quasi-voluntary disclosure rather than enforceable obligations…companies [may] technically comply [with section 54] without taking meaningful action"^[1] to combat modern slavery (see here for our discussion on the calls for reform of UK corporate human rights-related obligations).

The Bill appears to seek to address some aspects of the Act that have been subject to longstanding criticism but does not address other important issues relating to responsible supply chains on which there have been calls for reform. The key changes to the Act that are proposed in the Bill are summarised below.

1. Mandatory statement content now required

Under the current Act, organisations have discretion as to what to disclose in their slavery and human trafficking statements.  Currently, the Act states that organisations may include information on:

• their structure, business and supply chains,
• policies in relation to slavery and human trafficking,
• due diligence processes in relation to slavery and human trafficking in its business and supply chains,
• risk identification in its business and supply chains, and steps taken to assess and manage the risk,
• effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, with performance indicators as appropriate, and / or
• training about slavery and human trafficking available to its staff.

The Bill proposes mandatory content requirements for modern slavery statements. It identifies 6 topics that the statement must address. These mirror the 6 areas of information on which entities may report that are already set out in the Act, save that in respect of training, reporting entities would be required to provide information, where reasonably available, on training provided not only to their own staff but also to workers within their supply chains.

In relation to each topic, the Bill makes clear that the reporting obligation applies to information for the relevant financial year. In addition, for each topic where an organisation is unable to affirm the actions it has taken related to the required information, it would be required to state and explain why it has not taken those steps. This mirrors the 'comply or explain' approach already taken in the Act – a commercial organisation within the scope of the Act must produce a statement or explain why it has not done so. If these amendments are adopted, they would align more closely with the approach taken under the Australian Modern Slavery Act 2018, which already stipulates mandatory content requirements.

2. Approval requirements and statement of accuracy

The Bill maintains the approval requirements (which the Bill describes as "certification"), as well as the signature requirements. Additional requirements have been added. Firstly, the Bill proposes that the date of the approval and signature of the statement must be stated – this stipulation is currently voluntary as it is set out in guidance to the Act. The Bill also proposes that where the commercial organisation making the slavery and human trafficking statement is a subsidiary, then the statement must be "certified" either by it or by its parent company. The current position in statutory guidance is that a subsidiary can make its own statement, or a parent company may produce one statement covering its subsidiary.

Notably, the individual signing the statement would be required to declare that the statement is accurate to the best of their knowledge and belief. This declaration would potentially expand individual accountability for the signatories of slavery and human trafficking statements.

3. Extension to public authorities

At present, the Act only applies to commercial organisations whose turnover meets a certain threshold. The Bill proposes to impose an equivalent requirement on public authorities meeting a monetary threshold defined by budget to produce an annual slavery and human trafficking statement.

4. Timing requirement for production and publication

The Bill also introduces mandatory timing requirements, where statements must be published within 6 months of the end of the financial year to which the statement relates, again formalising guidance to the Act.

5. Financial penalties and enforcement

The Bill empowers the relevant Secretary of State to regulate for financial penalties to be imposed if a reporting entity fails "without reasonable excuse" to comply with a duty proposed under Part 5 of the Bill (i.e. regarding the preparation, contents, certification and publication of slavery and human trafficking statements). For commercial organisations, the maximum financial penalty would be 1% of its total turnover or £1 million, whichever is higher.

This marks a significant shift from the current position, where the only enforcement tool is injunctive relief on application of the relevant Secretary of State which, as far as we are aware, has never been used. In addition to introducing the financial penalty regime, the Bill also empowers the relevant Secretary of State to regulate for various other mechanisms to be used (e.g. requiring the enforcement authority to give a warning notice prior to the imposition of a financial penalty) as well as publication of information about organisations which have been fined.

Next steps and other legislative reform on human rights and modern slavery

As a bill introduced by the Government, the Bill would likely pass easily. That said, the Bill is subject to Parliamentary scrutiny and may be amended during its passage. Secondary legislation will also be required to bring several of the changes, including the penalty regime, into force.

The government has been under pressure to reform the Act for some time, alongside calls to introduce a forced labour ban and also to consider broader mandatory human rights due diligence ("mHRDD") legislation. The government has indicated that its stance on mHRDD (as well as any forced labour ban) would be unveiled in the Responsible Business Conduct Review that was due last quarter. See our previous blog post here.   

The Minister of Trade, Sir Chris Bryant MP, recently reiterated the government's commitments to considering both mHRDD legislation and a forced labour ban, while addressing the Business and Trade Committee of the House of Commons inquiry session on 30 June 2026. Whether or not more formal commitments are made is still to be seen, as the Responsible Business Conduct Review is still awaited.

_{¹ IASC, Strengthening the UK’s Forced Labour and Human Rights Legislative Framework, December 2025, p. 19.}