UK government publishes updated guidance on modern slavery reporting: what this means for businesses

Key takeaways for businesses

• The UK government has updated the guidance accompanying the section 54 reporting requirement in the Modern Slavery Act 2015. 
• The new guidance significantly increases expectations on the level of detail to be included in modern slavery statements and places a heightened focus on action and impact in practice. 
• The guidance is unlikely to be relevant for reporting this year in respect of FY2024 but organisations which are still to publish should consider the baseline disclosures for easy win areas of uplift.
• Companies should familiarise themselves with the guidance and develop an action plan for the remainder of 2025 to position themselves for reporting in 2026. 

Updated guidance published 

On 25 March 2025, the UK government published updated guidance (the Guidance) on the content of modern slavery statements (MSA Statements) published pursuant to section 54 of the Modern Slavery Act 2015 (MSA 2015). This updated Guidance reflects a commitment in the UK government’s response to the House of Lords Select Committee Report on the MSA 2015 in December 2024 (see our previous blog post).

Despite the various recommendations in the Select Committee Report, the Guidance does not go so far as to alter the core requirements of the MSA 2015 or make reporting on the current six suggested reporting areas mandatory. However, it does provide more detailed and practical information on what the UK government (and broader stakeholders) expect to be disclosed in statements and sets out how organisations can comply with the spirit of the MSA 2015 reporting requirement, and not just the letter of the law. 

In this blog post, we have summarised the key updates in the Guidance and what they mean for businesses in practice. For a refresher of the core requirements under the MSA 2015, see our previous blog post. 

Reporting expectations

The new Guidance significantly increases clarity on the specific information that organisations could include in their MSA Statements in response to each of the suggested reporting areas. The new Guidance appears to focus heavily on implementation of commitments, policies and processes in practice (e.g., through repeated references to the provision of case studies), responding to a common stakeholder criticism of MSA Statements that it is not clear how organisations are delivering on their disclosures. 

Structurally, within each reporting area, the Guidance adopts a new approach by establishing two tiers of disclosure: 

• Level 1 disclosures require businesses to provide basic, yet pivotal, information regarding actions to combat modern slavery. These disclosures are positioned as the baseline, to be used in the first year of compliance (although it is not clear whether this relates to the first year of compliance with the new Guidance, or first year reporting under the MSA 2015).
• Level 2 disclosures go a step further, prompting organisations to furnish more comprehensive information. The Guidance encourages organisations to progress to making Level 2 disclosures “as [they] become more familiar with the reporting requirements.”

Although positioned as a baseline, it is worth companies noting that some of the Level 1 disclosures go beyond what is typically seen in many MSA Statements. This includes providing an explanation of limitations in an organisation’s supply chain mapping and increased levels of detail on stakeholder engagement activities. 

The most obvious area where expectations have been increased, however, relates to monitoring and effectiveness – the reporting area most often criticised by stakeholders as not providing enough information. This is one area likely to require engagement and uplift by organisations ahead of preparing their next MSA Statement to be in a position to provide the desired information. 

Transparency and continuous improvement

Following the MSA 2015 reaching its tenth anniversary, the Guidance also provides a much keener focus on continuous improvement, with companies pushed in respect of each of the suggested areas, to provide detail on how their approach has changed from the previous statement and outline plans to improve going forwards. As a result, stakeholders may now expect to see more variation and development of statements year-on-year, with the indirect effect being that more substantive action will need to be taken by companies to enable them to be in a position to report against these suggested (Level 1) disclosures. 

The nexus between disclosures and action

When introduced, the MSA 2015 put the UK as a front runner on corporate responsibility and transparency. As it passes its tenth anniversary, however, the regime has been criticised as outdated in comparison to similar reporting regimes (e.g., in Australia) and substantive due diligence requirements introduced in Europe (e.g., the Corporate Sustainability Due Diligence Directive (CSDDD / CS3D), German Supply Chain Due Diligence Act and French Devoir de Vigilance) and being developed elsewhere (e.g., Thailand). 

Both the previous and current UK government have been steadfast in their support of the MSA 2015 as the answer to the risks of modern slavery and human trafficking and have defied calls, including those recently made by the Select Committee and Independent Anti-Slavery Commissioner, for the introduction of a more substantive regime. 

The Guidance, however, goes beyond disclosures and gives centre stage to the OECD Guidelines for Multinational Enterprises (and accompanying Due Diligence Guidance) and UN Guiding Principles on Business and Human Rights. These are the core soft law standards around which there has been much business convergence, and which form the basis of the substantive due diligence regimes introduced since the MSA 2015. Their central positioning and the embedding within the Guidance of “Key actions to consider” may be interpreted as softer support for mandatory action and could provide a strong lever for stakeholders looking to hold organisations accountable under the UNGPs and the OECD Guidelines at a time when there are increasing attempts to hold companies in the UK responsible for impacts caused by subsidiaries and suppliers. 

Mapping of supply chains beyond Tier 1

In keeping with the push for more action and closer alignment with the soft law standards, and in light of stakeholder criticism (e.g., by the UK’s Independent Anti-Slavery Commissioner, the Financial Reporting Council, and BankTrack), the Guidance is more explicit in describing how organisations should map their supply chain beyond their direct tier 1 suppliers to also seek to understand and map their indirect supply chains and  assess and manage the risks associated with them.  

In contrast to the carve-out under the EU CSDDD, the Guidance also refers to the specific downstream risks that financial institutions may need to consider, particularly in respect of their investee companies and customers. The Guidance also calls out the risks of facilitating the flow of finances for traffickers. 

What next?

Given the timing of its publication, this Guidance will likely be more relevant for the next reporting cycle in 2026 (in respect of FY2025) rather than the MSA Statements being published this year. 

However, for organisations still to publish their statements for this year, it would be worthwhile to have in mind the Guidance (and particularly the Level 1 disclosures) to see whether there are any low-hanging fruit that can be addressed in their MSA Statement. 

Over the rest of 2025, organisations would be well-advised to consider the Guidance and its recommended key actions, consider these against existing policies, practices and processes, and consider whether there are any actions that could be taken to position themselves well to report against the Guidance (both Level 1 and Level 2) in 2026.