Modern slavery reporting requirements in the UK: the statement, what the law asks and what is coming

Under section 54 of the Modern Slavery Act 2015, a commercial organisation that supplies goods or services, carries on business in the UK and has total turnover of £36 million or more must prepare a slavery and human trafficking statement for each financial year.

It must set out the steps taken to ensure slavery and human trafficking is not taking place in its supply chains and its own business, or state that no such steps were taken; be approved by the board and signed by a director; and be published on its website with a prominent link on the homepage.

A body corporate or partnership, wherever incorporated or formed, that carries on a business or part of a business in any part of the UK, supplies goods or services, and has total turnover of at least £36 million.

Total turnover includes the turnover of its subsidiary undertakings, including those outside the UK.

Total turnover of the organisation and its subsidiary undertakings, wherever those subsidiaries operate, under regulation 3 of SI 2015/1833.

Turnover is net of trade discounts, VAT and other taxes based on it. It is a single turnover test, not a two-of-three size test.

Legally, a statement of the steps the organisation took during the financial year to ensure slavery and human trafficking is not taking place in its supply chains and own business, or a statement that it took no such steps.

Section 54(5) lists six areas it “may” include — structure and supply chains, policies, due diligence, risk, effectiveness and training — and the Home Office guidance expects them to be covered, but they are not currently legally required.

Organisational structure, business and supply chains; policies on slavery and human trafficking; due diligence processes; the parts of the business and supply chains at risk and how that risk is assessed and managed; effectiveness measured against performance indicators; and training available to staff.

They come from section 54(5)(a) to (f).

For a company, it must be approved by the board of directors (or equivalent management body) and signed by a director (or equivalent).

For an LLP, it is approved by the members and signed by a designated member; for a limited partnership, signed by a general partner; for any other partnership, signed by a partner.

On the organisation’s website, with a link to it in a prominent place on the homepage, under section 54(7).

An organisation without a website must give a copy to anyone who asks in writing, within 30 days.

Home Office guidance says a link visible on the homepage or in an obvious drop-down menu, clearly labelled, meets the prominence test.

Section 54 sets no deadline beyond a statement for each financial year.

The Home Office guidance says it should be published as soon as possible after the year end and at most within six months.

The Immigration and Asylum Bill would make six months a legal deadline, but it is not law as at 11 October 2026.

No. The registry, launched on 11 March 2021, is voluntary; section 54 contains no duty to file there.

The government strongly encourages uploading, and the registry says it “will be mandatory in the future”.

The Immigration and Asylum Bill would allow regulations requiring electronic submission.

There is no fine in section 54.

The Secretary of State may bring civil proceedings in the High Court for an injunction (or specific performance in Scotland), and breaching an injunction is contempt of court, punishable by an unlimited fine according to the Home Office guidance.

The Immigration and Asylum Bill proposes financial penalties of up to the higher of £1 million or 1% of turnover.

Yes.

A parent may publish one statement that in-scope subsidiaries use, provided it covers the steps taken by each organisation required to report.

Home Office guidance says it should name the parent and subsidiaries covered and be published on the UK websites of all of them.

Yes, if they meet the tests.

In deciding whether a charity reaches £36 million, the guidance counts income from business activities such as the provision of goods and services for a fee; donations, legacies and grants where the donor receives no service or benefit are generally excluded.

Yes, if they carry on a business or part of a business in the UK and meet the other tests.

The guidance applies a common-sense test of demonstrable UK business presence, and says owning a UK subsidiary does not by itself mean the parent carries on business in the UK.

Not under current law: section 54 applies to commercial organisations.

Many public bodies publish voluntarily, and the government published the first Government Modern Slavery Statement in March 2020.

The Immigration and Asylum Bill would extend the duty to public authorities above a budget threshold set by regulations.

Yes, under section 54(4)(b) a statement that the organisation has taken no such steps is legally sufficient today.

The Home Office warns it may damage reputation, and the Immigration and Asylum Bill would require reasons wherever a required step was not taken.

Yes, one for each financial year in which the organisation meets the tests.

The guidance also recommends keeping earlier statements online and continuing to publish if turnover later falls below £36 million.

No. Both use £36 million, but the modern slavery test is a single total-turnover test including subsidiaries, while SECR applies to a company that exceeds two of £36 million turnover, £18 million balance sheet and 250 employees.

The figures coincide; the tests do not.

As introduced on 30 June 2026 it would make the content mandatory under a new Schedule 4ZA, require a director’s accuracy declaration and dated approval, allow a parent to certify a subsidiary’s statement, extend the duty to public authorities, set a six-month publication deadline, allow mandatory electronic submission, and allow financial penalties.

It is a bill in committee stage as at 11 October 2026, not law.

Yes, indirectly.

Under the Procurement Act 2023, certain Modern Slavery Act convictions are mandatory exclusion grounds and evidence of modern slavery can be a discretionary ground, and PPN 009 tells central government buyers to identify and manage modern slavery risk in their supply chains.

There is no statutory template.

The Home Office publishes an optional international reporting template, prepared with the Australian and Canadian governments, that supports one report for all three countries.