ESG Quick Guide: UK Modern Slavery Act 2015: modern slavery statements

The section 54 of the MSA 2015 requires in-scope organisations to publish an annual slavery and human trafficking statement (an “MSA Statement”) setting out the steps they have taken to ensure that modern slavery and human trafficking are not taking place in any part of their business or supply chains. 

The MSA 2015 has relatively light compliance requirements and does not mandate the content to be included in the MSA Statement. However, it does have suggested reporting areas that are fleshed out in non-binding government guidance.

The Government has proposed changes to section 54 of the MSA via Part 5 of the Immigration and Asylum Bill, which (if adopted) would make the content of MSA Statements mandatory and introduce financial penalties (see “Future changes” below). 

Mandatory for in-scope companies 

The requirement to produce an MSA Statement in section 54 of the MSA 2015 applies to organisations that:

• are a ‘body corporate’ or partnership (wherever incorporated/formed);
• carry on (part of) a business in (any part of) the UK;
• supply goods or services; and
• have an annual turnover of £36 million or more (calculated as the turnover of the specific entity and its subsidiary undertakings).

The MSA 2015 can apply to overseas organisations with a presence in the UK. 

There is no bright line guidance on the interpretation of “carrying on a business in the UK”, although the government guidance indicates “a common-sense” approach should be applied. 

Organisations that do not have a “demonstrable business presence” in the UK should not be in scope. 

The government guidance makes clear that having a UK subsidiary will not, in itself, mean an overseas parent company is carrying on a business in the UK.

Compliance requirements 

Organisations are required to: 

• publish an MSA Statement for each financial year (within six months of the end of the relevant financial year);
• have the MSA Statement approved by the board of directors and signed by a director (for LLPs, be approved by the members and signed by a designated member); and
• publish the MSA Statement on their website with a prominent link on the homepage (or provide a copy of the MSA Statement upon request in writing if you have no website).

Where a parent and one or more subsidiaries are required to publish an MSA Statement, it is possible for the parent to report at a group level on behalf of all in-scope entities. 

Non-mandatory content requirements

The MSA 2015 does not set out any mandatory content requirements. However, it does have suggested reporting areas that are fleshed out in the non-binding government guidance. 

The suggested reporting areas are:

• organisational structure, business, and supply chains;
• policies in relation to slavery and human trafficking;
• due diligence processes in the entities' business and supply chains;
• the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk;
• effectiveness in ensuring slavery and human trafficking are not taking place, measured against appropriate performance indicators; and
• the training about slavery and human trafficking available to its staff.

Government guidance and reporting template

The government has published a reporting template to support reporting under the regime (see below). 

The reporting template and the non-binding government guidance set out two tiers of disclosure:

• Level 1 disclosures are basic information regarding actions to combat modern slavery.
• Level 2 disclosures are more comprehensive information demonstrating progress and leadership in supply chain transparency. The guidance encourages organisations to progress to making Level 2 disclosures as they become more familiar with the reporting requirements.

Voluntary modern slavery statement registry

Organisations are encouraged to voluntarily upload their MSA Statement to the government’s modern slavery statement registry.

N/A

Publication of an MSA Statement is enforceable by a Secretary of State injunction. 

We are not aware of this power having ever been used.

The UK government announced in June 2025, as part of its Trade Strategy, a comprehensive review of its approach to responsible business conduct ("RBC"), responding to mounting concerns about the effectiveness of existing measures in tackling human rights abuses, labour exploitation and environmental damage in supply chains. 

The critical question now is which, if any, of the recommendations made so far the government will adopt, and whether the UK will align more closely with the EU's approach.

In July 2025, the UK Parliament’s Joint Committee on Human Rights published a report summarising the conclusions from its inquiry into the UK’s current legal and voluntary framework on forced labour in international supply chains. The Committee:

• found that the UK’s patchwork of domestic legislation relevant to forced labour and supply chains has not prevented goods linked to forced labour from entering the UK market;
• concluded that the UK is falling behind its main trading partners (such as the US and EU) in its approach to addressing forced labour in supply chains and new legislation is needed to ensure that the UK market is protected from goods tainted by forced labour;
• recommended the introduction of new legislation within one year that covers a new mandatory human rights due diligence duty, a right of action for victims of forced labour and a targeted import ban, as well as updates to the existing MSA 2015; and
• made several recommendations falling short of new legislation, including making it an explicit Government policy to include provisions concerning forced labour in future trade deals.

The government has not yet indicated whether it plans to take forward any of these recommendations. For more information, see our blog post. 

In December 2025, the UK Independent Anti-Slavery Commissioner’s ("IASC") published a report on Strengthening the UK’s Forced Labour and Human Rights Legislative Framework, with its “Model Legislative Drafting”. The IASC recommended the following:

• Failure to prevent offence: Similar to the AML/ABC space, the IASC has proposed a failure to prevent offence linked to serious human rights harms. This would include a reasonable due diligence defence and would apply to a broad range of companies, with the scoping test based on the current MSA with its £36m turnover threshold.
• Changes to MSA and due diligence regime: Section 54 of the MSA would be replaced with a broader human rights due diligence disclosure regime (via online annual statement) – with the reporting requirement backed by financial penalties.
• Forced labour ban: As well as a due diligence regime, the proposal includes a market access regime, proposing a ban on the export, import or making available of forced labour products (i.e., those made or transported with forced labour, including intermingled goods).
• Civil & criminal liability: The proposal introduces the potential for regulatory fines for a variety of offences (up to 5% turnover), civil liability (granting impacted stakeholders and their representatives a direct cause of action, including the possibility for exemplary damages and account of profits) and criminal liability (for egregious harms that would be criminal offences under UK law) with unlimited fines and the possibility for director liability (where they consent or connive to the conduct).
• Financial institutions & services: Unlike the EU Corporate Sustainability Due Diligence Directive (CSDDD or CS3D), the IASC’s proposed regime would not carve out financial institutions and would capture financial services, including investments and advisory services offered by investment managers.
• For more information, see our blog post. 

In May 2026, the Independent Anti-Slavery Commissioner published a report warning that renewable supply chains are at high risk of forced labor because of the rapid growth the sector is undergoing.

In June 2026, the Government introduced the Immigration and Asylum Bill into the House of Commons. Part 5 of the Bill proposes significant amendments to section 54 of the MSA: 

• The Bill (if adopted) would make the content of MSA Statements  mandatory. In-scope organisations would be required to report against prescribed topics set out in a new Schedule 4ZA to the MSA, including risk assessments, policies, due diligence processes, training, and effectiveness measures.

• MSA Statements would need to include an accuracy declaration where the signatory would be required to declare that the statement is accurate to the best of their knowledge and belief. Parent undertakings would be permitted to approve and sign statements on behalf of subsidiaries.

• Modern slavery reporting would be extended to public authorities above a financial threshold to be set in secondary legislation.

• A financial penalty regime would be introduced for non-compliance, with fines of up to the greater of £1 million or 1% of the organisation’s total turnover.

• The existing six-month publication deadline, currently set out in statutory guidance only, would become a statutory requirement. Organisations may also be required to submit statements electronically to the Secretary of State.

• The Bill does not go so far as to mandate human rights due diligence on supply chains, despite previous recommendations, including from the Joint Committee on Human Rights and the IASC. The Government is still considering this as part of its wider review of the UK’s approach to responsible business conduct. 

• Also in June, a separate Private Members’ Bill, the Commercial Organisations and Public Authorities Duty (Human Rights and Environment) Bill, was introduced in the House of Lords by Baroness Young of Hornsey. That Bill would impose a duty to prevent human rights and environmental harms, with a requirement to conduct due diligence and backed by civil and criminal liability, director liability (including imprisonment), and penalties of up to 10% of global turnover. However, Private Members’ Bills without Government backing rarely succeed and in its current form it is doubtful that this Bill would be passed (as with the prior version of the Bill introduced in 2023).

• For more information, see our blog post.

On 30 July 2025, the Home Office published a voluntary international reporting template to help organisations meet modern slavery, forced labour and child labour reporting requirements across the UK, Australia and Canada. 

The template is designed to streamline compliance for multinational organisations facing overlapping obligations, reducing administrative burdens by enabling the preparation of a single report that addresses the core disclosure requirements of all three jurisdictions. 

Organisations must still consult and comply with the specific legislation and official guidance in each country, including any administrative requirements and reporting deadlines. 

Key features of the template include:

• Reporting requirements grouped into seven themes - including organisational structure, policies, risk management processes, due diligence and remediation measures, employee training, and assessment of effectiveness of actions taken.
• Proportionate, risk-based reporting - focusing on material risks to people (rather than organisational risk such as reputational or financial harm).
• Two-level reporting, with the intention to encourage progress and improvement in year-on-year reporting requirements. Reporting requirements are split into two categories: level 1 disclosures being the core disclosure requirements that generally meet or exceed minimum obligations, and level 2 disclosures being recommended enhanced disclosures to demonstrate progress, leadership and continuous improvement in supply chain transparency. 

• Modern Slavery Act 2015
• Government guidance
• Modern slavery reporting template
• Modern slavery statement registry
• Immigration and Asylum Bill - see Part 5 of the Bill 

• UK government proposes mandatory disclosures and financial penalties for modern slavery reporting
• Unpacking the UK Modern Slavery Act 2015 eight years on
• UK government publishes updated guidance on modern slavery reporting: what this means for businesses
• Joint Committee on Human Rights publishes report on forced labour in UK supply chains
• UK government launches modern slavery statement registry
• UK: IASC report proposes new measures to strengthen human rights and forced labour framework
• ESG Quick Guide: EU Corporate Sustainability Due Diligence Directive (CSDDD / CS3D)
• ESG Quick Guide: EU Forced Labour Regulation
• Linklaters collection of materials: Business and Human Rights
• Linklaters collection of materials: EU CSDDD explained