When it first came into force ten years ago, many hailed the Modern Slavery Act 2015 (the Act) as a ‘world-leading’ piece of legislation in the fight against modern slavery. The Act was among the first legal frameworks to impose obligations on large businesses to scrutinise and report on forced labour and human trafficking within their supply chains. Despite this initial positivity, in the decade that has followed, critics have highlighted the fact that the Act “lacks teeth” and enforcement hasn’t been as meaningful as promised. The act was criticised most recently in the House of Lords, where it was argued that the legislation is “too limited to have significant practical impact”.
Now, in 2025, with global supply chains more complex and interconnected than ever, the Government has updated the Home Office’s Transparency in Supply Chains (TISC) guidance (the Guidance). The Guidance was first made available alongside the Act in October 2015 and is designed to provide practical guidance to in-scope businesses by explaining how they should comply with their obligations under section 54 of the Act. As a reminder, section 54 of the Act applies to large commercial organisations with a global annual turnover of £36 million or more, carrying on a business (or part of a business) in the UK.
Shifting from compliance to action
This latest edition of the Guidance signifies a renewed focus on compliance. It urges businesses to move beyond box-ticking and to instead enact meaningful changes within their supply chain by effective due diligence and increased transparency. Essentially, it encourages organisations not merely to meet the letter of the law, but to embrace its spirit. An acknowledgement of the existence of slavery risks within their businesses and supply chains is a foundational first step. This acceptance will better enable an organisation to address any such risks, and to embed appropriate anti-slavery efforts into broader corporate strategy. To illustrate this point, the Minister for Safeguarding and Violence Against Women and Girls, Jess Phillips, has stressed that organisations that fail to identify risks and cases as part of their statutory obligations are “probably not looking hard enough”.
What businesses need to know
Businesses who must comply with Section 54, should pay close attention to the following changes:
- A new two-tier system of disclosures in relation to the recommended statement disclosures which will distinguish between organisations, drafting their statements for the first time, and organisations that are more familiar with the reporting requirements. The latter group should provide deeper insights and demonstrate progress over time, continuously improving their practices;
- The clarification that while it remains permissible for a parent company to produce a single statement that its in-scope subsidiaries can also use, if the various organisations within a group structure operate across different sectors (and therefore attract different risks and responses) it is best practice for each in-scope organisation to produce their own tailored statement rather than relying on the parent company’s statement; and
- The promotion of the Government’s Modern Slavery Statement Registry and the express encouragement of businesses to upload their statements to the centralised platform to allow for greater transparency and public scrutiny.
The Guidance also highlights the growing importance of modern slavery risk management underpinning Environmental, Social, and Governance (ESG) considerations. It recommends that businesses integrate anti-slavery efforts into a broader, unified strategy for risk mapping, due diligence, and remediation.
How far do the changes actually go?
It’s important to note that, despite these updates clearly indicating the direction of travel that the Government intends to take on modern slavery reporting, the Guidance, by its nature, will not introduce any new mandatory requirements, with many of its recommendations remaining voluntary. Absent a legislative amendment, the introduction of the long awaited financial penalties for non-compliance or new civil enforcement powers remain out of reach. It’s notable that the Government hasn’t issued a single injunction since the Act’s inception.
In practice, this means that businesses are unlikely to face legal consequences for publishing vague statements, or for failing to act on identified risks. Nevertheless, these businesses still face potentially increased risk of public scrutiny, procurement exclusion, and reputational damage to businesses still failing to observe the spirit of their Section 54 obligations. For leaders responsible for organisations’ supply chains, the conversation has shifted: it’s no longer enough to simply publish a statement – it’s about the substance, frequency of updates, and the actions that follow. As ESG standards tighten, those who fail to adapt risk losing their competitive edge.
Where do we go from here?
Modern slavery is a current business risk, one that affects reputation, regulation, and responsibility. The Guidance challenges businesses to engage more deeply, act responsibly, and protect vulnerable workers, all while future-proofing their supply chains. Stronger legislation may be on the horizon. Irrespective of when it emerges, wider societal, economic (including from investors) and consumer pressures are driving organisations to better map, undertake due diligence and more clearly report on their supply chains and their associated risks.
In turn, this has led to a tightening of supplier contracts.
The return of the modern slavery brief to the Safeguarding Minister signals renewed political commitment, but real progress will require legislative reform. The updated Guidance is a wake-up call. Businesses need to act now or risk falling behind on public and investor expectations, and being excluded from ethical supply chains.
- Risk & Resilience
- Sourcing & Procurement