UK Modern Slavery Reporting: What the Immigration and Asylum Bill Means for Business Compliance

The UK’s corporate modern slavery regime is going to change dramatically. With mandatory content requirements, publishing deadlines, and penalties of up to the higher of 1% of turnover or GBP1 million, organisations cannot afford to be unprepared.

Since 2015, the UK’s Modern Slavery Act has required organisations in scope to publish annual statements about the steps they have taken to ensure there is no slavery in their operations and supply chains. In theory, it was a landmark law, widely regarded as the first of its kind globally. In practice, its impact has been limited with no mandatory content requirements and there never having been any enforcement action. All that is about to change. 

On 30 June 2026, the UK Government introduced the Immigration and Asylum Bill 2026, which contains significant amendments to the Modern Slavery Act. The Bill passed its Second Reading in the House of Commons on 13 July 2026 and is now making its way through Parliament.

 

What’s new?

Mandatory content

At the heart of the changes is a shift from discretionary to mandatory reporting content.

Under the current regime a statement “may” include organisational structure, policies, risk assessment, due diligence, training, and effectiveness. In practice, this is left entirely to an organisation’s discretion, meaning an organisation can currently publish a statement that addresses none of these areas.

The Bill fundamentally changes this position by requiring reporting against six mandatory pillars:

1. Organisational structure, operations, and supply chains: information on how the organisation is structured and where it sources goods and services throughout its supply chain.

2. Risk identification and mitigation: the areas of the organisation’s operations and supply chains where there is a risk of slavery or human trafficking, and the steps taken to assess, reduce, or remove that risk.

3. Policies: details of policies relating to modern slavery and human trafficking.

4. Due diligence processes: an explanation of due diligence measures implemented to identify and manage modern slavery risks.

5. Training: information on training provided to staff on modern slavery issues.

6. Effectiveness: an assessment of the effectiveness of the organisation’s efforts to prevent slavery, measured against appropriate key performance indicators.

Reporting will operate on a “comply or explain” basis.  Organisations will be required either to report on each of the six pillars or explain why relevant steps have not been taken

The requirement to assess the effectiveness of anti-slavery measures is particularly significant. The days of simply recycling annual statements are over. The new regime is intended to drive continuous improvement and meaningful engagement with modern slavery risks.

 

 

New financial penalties

The introduction of financial penalties will bring real enforcement powers to a regime that currently lacks them.

The Secretary of State will be empowered to make regulations imposing financial penalties on organisations that, “without reasonable excuse”, fail to comply with their obligations.

The statutory cap is set at the higher of:

• 1% of the organisation’s total turnover (or total budget for public authorities); or
• GPB1 million.

 A “reasonable excuse” defence will be available, and the regulations must provide organisations with warning notices and an opportunity to make representations before a penalty is imposed. However, it remains to be seen in what circumstances that defence will successfully be available.

Importantly, the penalty regime is not limited to failure to publish a statement. It applies to failure to comply with any statutory duty and could therefore include defective content, missed publication deadlines, or failures to submit information in the prescribed form.

Deadlines, director declaration and board certification

The Bill also introduces a mandatory publication deadline of six months after the end of the organisation’s financial year.

By contrast, existing Government guidance merely recommends publication “as soon as possible” within six months.

Board-level oversight will also be strengthened. Annual statements must as now be approved by the board of directors (or equivalent governing body) and signed by a director.

What is new is that the director signatory must make a personal declaration that the content of the statement is “accurate to the best of their knowledge and belief”. This increases individual accountability for the content of modern slavery disclosures.

It is easy to envisage circumstances in which campaign groups and other stakeholders may focus scrutiny on the individual signatory. The relevant director will, therefore, need to be appropriately-advised and satisfied as to the accuracy and robustness of the information being disclosed.

A further welcome change is the ability for a parent company to approve a modern slavery statement on behalf of its subsidiaries, representing a practical improvement for corporate groups.

Extension to public authorities

For the first time, the reporting regime will be extended to public authorities that meet financial thresholds to be determined by future regulations.

This is likely to have a cascading effect throughout public procurement supply chains, as public authorities may increasingly require enhanced modern slavery reporting and due diligence from their contractors and suppliers.

How organisations should prepare now

The amendments will not come into force immediately upon Royal Assent, a commencement date will need to be specified through secondary legislation.

Nevertheless, organisations should begin preparing now by considering the following questions:

• Is the supply chain properly mapped across all tiers?
• How will modern slavery risks be identified and assessed?
• What actions will be taken where risks are identified?
• Is sufficient data available to support and verify public disclosures?
• Are governance structures robust enough to support board level approval and director certification?
• What due diligence processes, policies and training programmes will be required?
• How will effectiveness be measured and demonstrated?

The proposed reforms mark the most significant overhaul of the UK’s modern slavery reporting regime since its introduction in 2015. While the detail of implementation remains to be seen, organisations should not underestimate the scale of the compliance challenge ahead.

 

Further information