UK government responds to House of Lords Select Committee Report on Modern Slavery Act 2015

At the end of December 2024, the UK government published its response to the House of Lords Select Committee on the Modern Slavery Act 2015 (MSA Committee) report on the impact and effectiveness of the Modern Slavery Act 2015 (MSA 2015), putting forth recommendations to align  the UK regime with international best practices.

For more information on the MSA Committee report, see our previous blog post. 

Government response 

In this blog post, we explore the UK government's response to the key recommendations from the MSA Committee, highlighting significant areas such as supply chain due diligence, import bans, mandatory reporting, new guidance, and enforcement.

Supply chain due diligence

The MSA Committee report recommended introducing mandatory due diligence requirements to align with international best practice. However, consistent with the previous government’s refusal to introduce a UK equivalent to the EU Corporate Sustainability Due Diligence Directive (CSDDD / CS3D), the current UK government reaffirmed its support for the existing voluntary due diligence approach currently taken by UK businesses in line with the UN Guiding Principles on Business and Human Rights (UNGPs) and the Organisation for Economic Co-operation and Development’s (OECD) Guidelines for Multinational Enterprises. 

Nonetheless, the UK government indicated that it is keeping this under review, with the Foreign, Commonwealth and Development Office (FCDO) in the process of conducting a baseline assessment on the implementation of the UNGPs in the UK to help inform the UK government’s approach to tackling business-related human rights abuses. 

Since the government’s response, the new Independent Anti-Slavery Commissioner (IASC, appointed after a twenty-month vacancy) has published their strategy for 2024-2026. The strategy encourages a strengthening of the current UK policy response to forced labour in domestic and global supply chains and advocates for the introduction of mandatory human rights due diligence legislation. Whether this sways the government to action, however, remains to be seen. 

Import bans 

The UK government has confirmed that it is continuing to evaluate the effectiveness of existing measures. 

Mandatory reporting requirements

The MSA Committee recommended making the publication of statements on the government’s modern slavery registry mandatory, as well as calling on the UK government to clearly set out the topics that companies are required to cover within their statements. The IASC echoed these calls, noting the existing disparities in modern slavery statements and the limited evidence of downstream outcomes and the quality of statements. 

In response, the UK government confirmed its intention to work on its existing improvements to the registry announced in April 2024, with the aim to increase the number of statements being uploaded (albeit still on a voluntary basis). 

New guidance for Section 54 compliance 

The MSA Committee report called for the publication of standardised guidance for the reporting requirements under section 54 of the MSA 2015. The UK government confirmed that it is in the process of working with stakeholders across business, academia and civil society to update the existing statutory guidance. 

However, the UK government did not provide a timing as to when the updated guidance might be made available. 

Enforcement

The MSA Committee report recommended the introduction of sanctions for organisations that do not comply with section 54 of the MSA 2015.

The UK government acknowledged that the existing regime (which gives the Home Secretary the power to seek an injunction) has not been used to-date due to cost challenges and difficulties in assessing compliance. 

In view of this, the UK government is reviewing how it can strengthen the enforcement framework but provided no specific timing or additional detail as to what this might look like.

Mandatory reporting for public bodies 

In response to the call to expand the section 54 reporting requirement to public bodies, the government stated that it is reviewing this position, but did not provide any specific timing or additional detail. 

What’s next?

While the UK government's response indicates ongoing reviews and potential changes, much remains undetermined. 

The UK Parliamentary Joint Committee on Human Rights launched an inquiry in January 2025 into forced labour in UK supply chains (see here). The inquiry will examine the UK's current legal and voluntary framework in relation to forced labour in international supply chains, and whether it is effective in managing forced labour exposure risks in the UK market, or if changes are required. However, it is not clear at this stage how the Joint Committee's findings will eventually feed into the government’s deliberations.

However, what is clear is that, as developments unfold, this is an area to continue monitoring to see how the UK modern slavery (and broader human rights) legislative landscape might evolve.

Further reading 

For more information on the EU CSDDD regime and human rights more generally, see:

• EU CSDDD explained
• Business and Human Rights materials