UK Modern Slavery Reporting: Who Must Publish and What to Include
UK modern slavery reporting means publishing an annual statement under Section 54 of the Modern Slavery Act 2015. It applies if your organisation carries on business in the UK, supplies goods or services, and has an annual turnover of at least £36 million. The statement sets out what you did in the last financial year to stop slavery and human trafficking in your operations and supply chains. It must be approved by your board, signed by a director and published on your website. This guide covers the current rules, what a good statement contains, and the reforms now proposed.
Key takeaways
You must publish a statement every financial year if you carry on business in the UK and your turnover is at least £36 million.
The board must approve it and a director (or a designated member of an LLP) must sign it. It goes on your UK website with a prominent homepage link.
Government guidance sets out six areas to cover, and today the law does not force you to address them. Proposed reforms would make them mandatory and add financial penalties.
A statement that shows real risk assessment, remediation and year-on-year progress is worth far more than a generic policy summary.
What UK modern slavery reporting actually requires
Section 54 is a transparency duty, not a duty to prove your supply chain is clean. The law asks you to say what you have done. If you have done nothing, you must say so. A statement must describe the steps taken during the financial year to manage modern slavery risks, or state that no steps were taken.
The idea is that investors, customers, journalists and campaigners can read the statements, compare them and press for better. That is why the publication rules matter as much as the content.
Who has to publish
Three conditions apply together, according to the official GOV.UK guidance. Your organisation must:
Be a body corporate or a partnership, wherever it is incorporated.
Carry on a business, or part of a business, in the UK.
Supply goods or services, with an annual turnover of at least £36 million.
Two points catch organisations out. First, a non-UK company with a UK presence can be caught. Second, the turnover test looks at the whole organisation and its group, not only the UK arm. If you are near the threshold, check the official guidance before assuming you are exempt.
Many organisations below the threshold publish a statement anyway, because large customers and public buyers ask for one in tender questionnaires. That is a commercial choice, not a legal duty.
How often
You prepare a statement for each financial year. LUPC advises publishing it within six months of the year end as best practice. Treat that as a working deadline: set the sign-off date in your board calendar at the start of the year, not after the accounts close.
What your statement should cover
The guidance identifies six areas a statement may include:
Area | What to explain |
Organisational structure and supply chains | What you do, where, and how your supply chains are built |
Policies | The policies on slavery, trafficking and responsible sourcing, and who owns them |
Risk assessment | Where in your operations and supply chains the risk is highest, and why |
Due diligence and remediation | The checks you run on suppliers and what you do when you find a problem |
Training | Who was trained, on what, and how you know it worked |
Monitoring and evaluation | The measures you use to judge whether your steps are effective |
These six areas come from the government’s practical guide, which also recommends showing progress year on year, disclosing the risks you have identified and reporting on remediation.
Go beyond the minimum
The weakest statements read like a copied policy. They say the company has zero tolerance and then describe nothing. A stronger statement:
Names the sectors, products and countries where you see the highest exposure.
Says what you found, including problems, and what you did about them.
Compares this year with last year, with measures you can track.
Explains how workers or affected people can raise concerns, and what happens next.
Civil society guidance from CORE makes the same point: good practice includes disclosing identified instances of modern slavery, corrective action plans, grievance mechanisms and any remedy provided. An honest account of a found problem and its fix is more credible than a claim that nothing was ever wrong.
Who signs it and where it goes
The approval chain is strict. Under the GOV.UK guidance, the board or equivalent management body must approve the statement. A director, or equivalent, must sign it. For an LLP, a designated member signs.
The explanatory notes to the Act explain why: senior sign-off is meant to ensure the statement has the backing of the people best placed to change things.
For publication:
Publish it on your UK website, with a prominent link on the homepage.
If you have no website, give a copy in writing to anyone who asks, within 30 days.
Upload it to the government’s registry. The modern slavery statement registry lists 34,339 registered organisations and 23,933 unique statements. At present, uploading is encouraged rather than compulsory.
How to build a statement, step by step
1. Map your supply chain
Start with direct suppliers, then work towards indirect ones. The official guide says organisations can map their supply chains, beginning with direct suppliers and seeking to understand indirect ones, to find high-risk areas. You will not see everything in the first year. Say what you could and could not see, and what you will do about the gaps.
2. Rank the risks
Score risk by product, location, supplier type and the way workers are hired. Labour-intensive, outsourced and seasonal work, such as cleaning, construction, agriculture and logistics, usually sits higher than a desk-based service. Write down why each area ranks where it does. That reasoning is what a reader looks for.
3. Act on what you find
The UN Guiding Principles on human rights due diligence, which the government guide draws on, follow a simple loop: assess impacts, act on findings, track responses and communicate how impacts are addressed. Your statement should show that loop working, with at least one concrete example of an action taken.
4. Train the right people
Training should reach the people who make decisions that affect risk, such as buyers and recruiters, and groups who may be at risk. CORE suggests evaluating training through participant feedback. Report who was trained and what changed afterwards, not only that a module exists.
5. Measure and report
Pick a small number of indicators you can repeat each year: share of high-risk suppliers audited, concerns raised and closed, training completion. Then report the same measures next year. Trends are what turn a statement into evidence of progress.
Reporting in the UK, Australia and Canada
If you operate in more than one of these countries, you may face three regimes. The UK, Australian and Canadian rules differ in requirements, definitions and scope. The UK government publishes an optional international reporting template designed to support one report across all three.
The template splits content into two levels. Level 1 is information organisations should disclose. Level 2 is recommended information that demonstrates progress and leadership. Even if you only report in the UK, this split is a handy way to decide what is essential and what is a stretch goal.
Organisations with European operations should also watch related supply-chain rules. Our guide to UK deforestation checks for business supply chains shows how due diligence duties are spreading across environmental and human rights topics, and our explainer on CSRD reporting covers the EU side.
Enforcement today and reforms on the way
The current enforcement route is narrow. If an organisation fails to comply, the Secretary of State may seek a court injunction requiring compliance, or specific performance in Scotland. In practice the main consequences have been reputational: investors, buyers and campaigners can see who has not published.
That looks set to change. According to a People Management analysis from September 2026, the proposed Immigration and Asylum Bill would amend Section 54 in several ways:
Reporting against the six prescribed topics would become mandatory, with an added assessment of effectiveness against performance indicators.
The signatory would give an accuracy declaration, confirming the statement is accurate to the best of their knowledge and belief.
The duty would extend to public authorities.
The Secretary of State could require electronic submission to the government registry.
Financial penalties would apply for non-compliance without reasonable excuse, capped at the higher of 1 per cent of turnover (or total budget for public authorities) or £1m.
These are proposals, so check the progress of the Bill and any regulations on GOV.UK before you rely on the detail. The direction is clear, though: a statement that is thin today is a risk tomorrow.
What to do now
Compare your last statement against the six areas and list the gaps.
Agree a board sign-off process that gives the signing director time to check the evidence.
Map your international supply chains, noting where suppliers may face other mandatory due diligence rules.
Set measures you can track from this year onwards.
Where Exereco can help
Many teams struggle less with the law than with gathering evidence from procurement, HR and operations into one consistent report. At Exereco we bring sustainability news, ESG advisory, training and reporting tools together for organisations in Europe and Africa. Our Human Rights Reporting course helps your team build the due diligence and disclosure skills a modern slavery statement relies on.
If your reporting also covers wider ESG topics, our GRI Reporting course and Corporate Social Responsibilities training fit alongside it. You can also read how SDG 8 on decent work connects to labour rights in supply chains.
FAQ
Is a modern slavery statement mandatory in the UK?
Yes, if you carry on business in the UK, supply goods or services and have a turnover of at least £36 million. You must publish one for each financial year. Organisations below the threshold are not legally required to, but many publish one voluntarily.
Who has to sign the statement?
The board or equivalent management body approves it, and a director or equivalent signs it. For an LLP, a designated member signs. Proposed reforms would add a personal accuracy declaration from the signatory.
Where must the statement be published?
On your UK website, with a prominent link on the homepage. If you have no website, you must give a copy in writing to anyone who requests it within 30 days. Uploading to the government registry is encouraged and may become a requirement.
What happens if we do not publish?
Currently the Secretary of State may seek a court injunction to require compliance, and reputational damage is the more common consequence. Proposed reforms would introduce financial penalties. Check GOV.UK for the current position before your next reporting cycle.
How is it different from the Australian and Canadian rules?
The three regimes differ in requirements, definitions and scope. The UK government’s optional international template is designed to let you produce one report covering all three, split into level 1 and level 2 disclosures.
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